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Full text of "Vinyl chloride monomer release from a railroad tank car and fire, Formosa Plastics Corporation Plant, Baton Rouge, Louisiana, July 30, 1983"

PB85-916308 



^-^^^^/b 



HE 

1780 
.U58 
85/08 





NATIONAL %r;rio^^ 

TRANSPORTATION 

SAFETY 

BOARD 

WASHINGTON, D.C. 20594 

RAILROAD ACCIDENT REPORT 



VINYL CHIORIDE MONOMER 

RELEASE FROM A 

RAILROAD TANK CAR AND FIRE 

FORMOSA PLASTICS CORPORATION PLANT 

BATON ROUGE, LOUISIANA 

JULY 30, 1983 

NTSB/RAR-85/08 



For Reference 

DO Not Tak« TES GOVERNMENT 

From the Library 



.US'? 



1 . Report No. 



eport NO. 
NTSB/RAR-85/08 



TECHNICAL REPORT DOCUMENTATION PAGE 



2 .Government Accession No. 
PB85-916308 



^. Title and Subt i tie Railroad Accident Report — 
Vinyl Chloride Monomer Release from a Railroad 
Tank Car and Fire, Formosa Plastics Corporation 
Plant, Baton Rouge, Louisiana, July 30, 1983 

7. Author(s) 



3 .Recipient 's Catalog No. 



5. Report Date 
May 14, 1985 



6 .Performi ng Organization 
Code 



8. Performing Organization 
Report No. 



9. Performing Organization Name and Address 

National Transportation Safety Board 
Bureau of Accident Investigation 
Washington, D.C. 20594 



10. Work Unit No. 
3793B 



11. Contract or Grant No. 



12. Sponsor ing Agency Name and Address 

NATIONAL TRANSPORTATION SAFETY BOARD 
Washington, D. C. 20594 



13 -Type of Report and 
Period Covered 

Railroad Accident Report 
July 30, 1984 



1 i» .Sponsor i ng Agency Code 



1 5. Supplementary Notes 



16. Abstract At 3:45 a.m., on July 30, 1983, vinyl chloride monomer (VCM) under 

pressure escaped from a railroad tank car at the loading facility within the Formosa 
Plastics Corporation chemical manufacturing plant at Baton Rouge, Louisiana. The 
released VCM was ignited by an undetermined source, and a large billowing fire ensued. 
An adjacent tank car containing VCM was involved in the fire but did not rupture 
violently. Two persons were injured seriously, two tank cars were destroyed, three tank 
cars were damaged moderately, and the loading facility was damaged extensively. 
Damage was estimated to be $1 million. 

The National Transportation Safety Board determines that the probable 
cause of the sudden release and ignition of vinyl chloride monomer from a loaded tank car 
was a plant employee's failure to close the tank car liquid valves and purge the 
pressurized vapor return and loading hoses before disconnecting them, and the presence of 
one or more sources of ignition at the loading rack. Contributing to the cause of the 
accident was the failure of the Formosa Plastics Corporation to maintain safe facilities 
for the loading of vinyl chloride monomer and to provide written procedures, adequate 
training, and supervision for its loading personnel. Also contributing to the cause of the 
accident were the improperly seated excess flow valves in the tank car. 



17- Key Words 

tank cars; loading rack; tank car 
fittings; tank car insulation; tank car loading 
fixtures, excess flow valves; ignition; vinyl 
chloride monomer; escape; emergency response 



l8.Di stri but ion Statement 

This document is available 
through the National Tech- 
nical Information Service, 
Springfield, Virginia, 22161 



19. Security Classification 
(of this report) 
UNCLASSIFIED 



20. Security Classification 
(of this page) 
UNCLASSIFIED 



21 .No. of Pages 
47 



22. Price 



NTSB Form 1765.2 (Rev. 9/74) 



CONTENTS 

SYNOPSIS 1 

INVESTIGATION 1 

The Accident 1 

Injuries to Persons 5 

Damage 5 

Tank Car Information 5 

Company, Personnel, and Training Information 6 

Facility Information 7 

Method of Operation 8 

Meteorological Information 9 

Ignition Sources 9 

Emergency Response 10 

Medical and Pathological Information 10 

Survival Aspects 10 

Tests and Research 11 

Other Information . 12 

ANALYSIS 13 

The Accident 13 

Excess Flow Valves 15 

Ignition Sources 15 

Training and Supervision 16 

Safety Oversight 16 

Tank Car Safeguards 17 

CONCLUSIONS 18 

Findings 18 

Probable Cause 18 

RECOMMENDATIONS 19 

APPENDIXES 23 

Appendix A— Investigation 23 

Appendix B— Formosa Procedure for Loading Vinyl Chloride Tank Cars . . 24 

Appendix C— Chemical Safety Data Sheet SD-56 30 



NATIONAL TRANSPORTATION SAFETY BOARD 
WASHINGTON, D.C. 20594 



RAILROAD ACCIDENT REPORT 



Adopted: May 14, 1985 



VINYL CHLORIDE MONOMER 

RELEASE FROM A RAILROAD TANK CAR AND FIRE 

FORMOSA PLASTICS CORPORATION PLANT 

BATON ROUGE, LOUISIANA 

JULY 30, 1983 

SYNOPSIS 

At 3:45 a.m., on July 30, 1983, vinyl chloride monomer (VCM) under pressure 
escaped from a railroad tank car at the loading facility within the Formosa Plastics 
Corporation chemical manufacturing plant at Baton Rouge, Louisiana. The released VCM 
was ignited by an undetermined source, and a large billowing fire ensued. An adjacent 
tank car containing VCM was involved in the fire but did not rupture violently. Two 
persons were injured seriously, two tank cars were destroyed, three tank cars were 
damaged moderately, and the loading facility was damaged extensively. Damage was 
estimated to be $1 million. 

The National Transportation Safety Board determines that the probable cause of the 
sudden release and ignition of vinyl chloride monomer from a loaded tank car was a plant 
employee's failure to close the tank car liquid valves and purge the pressurized vapor 
return and loading hoses before disconnecting them, and the presence of one or more 
sources of ignition at the loading rack. Contributing to the cause of the accident was the 
failure of the Formosa Plastics Corporation to maintain safe facilities for the loading of 
vinyl chloride monomer and to provide written procedures, adequate training, and 
supervision for its loading personnel. Also contributing to the cause of the accident were 
the improperly seated excess flow valves in the tank car. 

INVKTIGATION 

The Accident 

During the evening of July 29, 1983, an employee (loader-1) at the Formosa Plastics 
Corporation (Formosa) chemical manufacturing plant at Baton Rouge, Louisiana, was 
assigned to load vinyl chloride monomer (VCM) 1/ into five railroad tank cars located at 
station Nos. 5-1, 5-2, 5-3, 6-1, and 6-2 at the plant's VCM loading rack. After loading all 
five tank cars, he began to secure them for shipment, a process which includes closing the 
VCM supply valve on the loading rack, closing the liquid valves and vapor valve 2/ on tank 



1/ Classified by the U.S. Department of Transportation as a flammable compressed gas, 

VCM is ignited easily in either liquid or vapor form, producing hazardous combustible 

gases largely composed of hydrogen chloride and carbon monoxide. It also is classified as 

carcinogenic. 

2/ As liquid is loaded into a tank car, a vapor valve aUows the vapor inside the tank car 

to exhaust, thereby preventing pressure buildup inside the tank car and permitting a full 

load of liquid to be loaded. 



-2- 

cars, purging the liquid loading hoses of residual VCM with nitrogen, purging the vapor 
hoses with nitrogen, venting the hoses of nitrogen, releasing the locking cams on the 
quick-release coupler linking the loading hose to the liquid valve nipple, removing the 
hoses from the tank cars, and closing the tank car manway cover. (See figure 1.) He 
secured the tank car at station No. 5-2 but could not finish securing the four other tank 
cars because the pressure in the nitrogen supply line dropped to 90 psi because of other 
users. This pressure was too low to overcome the 120-psi pressure in the loaded tank 
cars. He said that on each of the four remaining tank cars, he closed off the vapor valve 
but left connected the vapor hose, which carries vapor from the tank car to the loading 
rack; left connected the two liquid loading hoses, which carry the liquid VCM from the 
loading rack to the tank car and in which was residual VCM; and left open the tank car 
liquid valves, which are located on the tank car where the liquid loading hoses are 
attached to liquid valve nipples during loading. (See figures 1 and 2.) 

Loader-1 drew samples of the VCM from the loaded tank cars to take to the plant 
laboratory for testing. Before he left for the laboratory about 3:30 a.m., loader-1 was 
joined by another employee (loader-2). Loader-1 explained to loader-2 that he had not 
finished securing for shipment the four remaining tank cars because of low nitrogen 
pressure. He then left the loading area for the laboratory. 

Loader-2 said that after loader-1 left, he crossed over the bridge from the loading 
rack onto the dome of the tank car located at station No. 6-2 (see figure 2) and stopped to 
look at the early morning sky. Loader-2 said that, as he did so, he was struck on the back 
by one of the VCM liquid loading hoses, which had come loose from its attachment to the 
tank car. (See figure 1.) Seeing pressurized VCM pouring from the liquid valve nipple and 
knowing that VCM is combustible, is carcinogenic, and freezes the skin on contact, he ran 
to the end of the tank car and slid down the side of the car to the ground below. He did 
not use the bridge from the tank dome to the loading rack to escape because the loose 
hose was between his position on the tank car and the bridge. The sudden outward flow of 
VCM was not stopped by the tank car's excess flow valve. 3/ (See figure 1.) VCM 
accumulated on the ground below and between the tank cars at station Nos. 6-2 and 5-2 
and was ignited by an undetermined source; a large billowing fire ensued. VCM spraying 
from the liquid valve nipple of the tank car at station No. 6-2 was ignited and, because of 
the angle of the valve nipple, burning VCM sprayed like a torch onto the tank car at 
station No. 5-2. When the other liquid loading hose on the tank car at station No. 6-2 was 
burned off, burning VCM also began spraying onto the tank car at station No. 5-2 from the 
car's other liquid valve nipple. 

Although severely burned, loader-2 crawled from the loading area. Another 
employee (loader-3), who was standing on a caustic soda loading rack nearby, smelled the 
VCM, turned toward the VCM loading rack, and was struck by a fireball. Although 
seriously burned, he immediately ran from the area. No one else was injured. 

Firefighters began to arrive onscene within 15 minutes, and they found both tank 
cars engulfed in flames. The fire in the tank car at station No. 6-2 burned out by 
midafternoon. The tank car at station No. 5-2 burned for 120 hours throughout which 
water was applied to cool the adjacent tank cars loaded with VCM. 



3/ A safety device designed to shut off the sudden outward flow of liquid in the event an 
external liquid valve is damaged or severed from the tank piping during transportation. 



-3- 



LIQUID 

LOADING 

HOSE 




LIQUID VALVE NIPPLE 



TOP VIEW 


g 
^ 


a^jj^vVAPOR 
^^"CVALVE 



EXCESS FLOW 
VALVE LOCATIONS 



LIQUID LINES 




Fi^re 1.— Side view of tank car with liquid loading hoses attached for loading, 
and top view (inset) of tank car shown without manway bonnet cover. 



-4- 




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-5- 



th. Jrf ^ the accident, investigators found that the safety valve 4/ (see figure 1) on 
P«l n^L r ^' ''^''?K ''°- ^"' ^^^ "°* ^^tivate during the fire. Loader-1 had laid the 
ZLZf H ^f"'^ }^^ ""^"^^^ ^°""^* "°^^'' °" t°P °f t^^ ««f^tv valve before the 
rpT.loH T V^f "^^^ "°* "°^^" ^^^y ^' ** ^°"1^ have been if the safety valve had 
released Investigators also found that the liquid loading and vapor hoses had been 
removed from the tank cars at station Nos. 5-1 and 6-1 and that aU of the valves anS 
manway covers on these tank cars had been closed before the accident 



Injuries to Persons 



Injuries 


Plant 
employees 


2 


Emergency response 
personnel 


Total 


Fatal 
Nonfatal 







2 


Total 


2 





2 


Damage 









TV. f-'^^!,^?'^ loading rack was damaged extensively between station Nos. 6-2 and 5-2. 
The fire destroyed the platform, crossover bridges, piping, and electrical lines. 

H ^•^!'^ }^fv. "^fu \^ ^*^^l°" ^°- ^~^ ^^^ destroyed. The steel outer jacket was burned 
and distorted by the heat of the fire, and the insulation was consumed by the fire. 

The tank car at station No. 5-2 also was destroyed. The steel outer jacket was 
burned, and the insulation at the top of the south end of the car was consumed by the fire. 
The tank car walkway and handrail melted and collapsed. The wall of the tank car 
manway protective housing and cover on the side nearest the fire melted. The tank car 
shell at the top of the south end of the car bulged, causing the metal to stretch and 
become thinned. The metal at the bulged area split, and a hole 2 3/8 inches long and 
1/2 inch wide developed. Five smaU holes developed in the stretched and thinned area at 
the side of the bulge. Built-up pressure began to release through the safety valve on the 
car at station No. 5-2 about 50 to 60 minutes after the fire began. This release of 
pressure prevented sufficient pressure from building in the tank car to cause a violent 
rupture of the tank sheU. The bulging and thinning of the shell metal and the holes and 
cracks that formed m the tank also allowed release of internal pressure. 

Three other tank cars in adjacent loading stations were damaged moderately by the 
heat of the fire. 

Tank Car Information 

The tank car at station No. 6-2, a U.S. Department of Transportation (DOT) 
specification 105A300W 5/ tank car built by the Union Tank Car Companv (Union) in 
March 1979, was owned by Union and was leased bv Formosa. It had a capacity of 24 859 
gallons, a light weight of 83,000 pounds, and was designed to have a fully loaded weight of 

4/ Th"e safety valvi was set to release when the internal pressure exceeded 247 psi and 
thereby prevent a violent rupture of the tank shell. 

5/ The numbers and letters in the DOT classification refer to the following: "105" (class 
designation), "A" (no significance), "300" (test pressure), "W" (welded construction) 



-6- 

180,000 pounds. The car was insulated with 1 inch of mineral wool and 3 inches of 
fiberglass. The tank shell and tank heads were 9 16-inch-thick steel. The tank shell was 
44 feet 2 1/2 inches long and had an outside diameter of 114 inches. A 1 /8-inch-thiek 
steel weather jacket covered the insulation and tank shell. 

The tank car at station No. 5-2 was built as a DOT specification 112A340W 6/ tank 
car by Union in November 1968. In 1975. the car was modified to reduce the capacity of 
the tank from 41.777 gallons to 27.382 gallons. In March 1980. the car was fitted with 
head shields. Korotherm insulation, and a steel weather jacket so that it would meet the 
requirements of specification ir2J3401V 7 '; the tank capacity was not changed. The tank 
sheU was 5.'8-inch-thick steel, and the tank heads were 11 IB-inch-thick steel. The tank 
shell was 48 feet 10 inches long and had an outside diameter of 119.3 inches. 

Both tank cars had two internal liquid lines through which chemicals could be 
loaded. The liquid lines extended into the tank from the manway entrance at the ear 
dome. (See figure 1.) Each liquid line was fitted at the manway entrance with a 
2-ineh-diameter. ball-type, steel-body angle valve containing a stainless steel ball. 
Directly under each liquid valve was a 3-inch-diameter excess flow valve. Each tank car 
also contained a vapor line through which chemical vapors could be vented during loading. 
The vapor line extended into the tank from the manway entrance. The vapor line was 
fitted at the manway entrance with a 2-inch-diameter. steel-body angle valve containing 
a stainless steel ball. Directly under the vapor valve was a 2-inch-diameter excess flow 
valve. Both cars were equipped with a safety valve and were stenciled to indicate that 
the valve was set at 247 psi. Both tank cars also were equipped with a sampling line, a 
gauging device, and a thermometer well at the manway entrance. 

Company, Personnel, and Training Information 

The chemical manufacturing plant was built by the Allied Chemical Company and 
later sold to the ICI Company. During the years that Allied and ICI owned the plant, 
railroad tank cars were loaded by employees assigned specifically for this purpose. The 
loaders so assigned usually worked one of three 8-hour shifts. 5 days a week. Depending 
on the production schedule, there may have been a 7-day loading ooeration on one shift, 
and at other times only two shifts loading 5 days a week. T\vo loaders always were 
assigned to work together on the ^'C!\I loading rack. A supervisor also was assigned to the 
tank car loading rack. Other operating department employees were assigned to the duties 
in the tank farm, to make pipeline deliveries, and to load trucks, barges, and seagoing 
vessels. 

ICI sold the plant to Formosa in 1981. Formosa has reorganized the plant operations 
and added supervision of the tank car loading operations to the duties of the supervisors at 
the powerhouse. Formosa has established two 12-hour shifts, from 6 a.m. to 6 p.m. and 
from 6 p.m. to 6 a.m. Two loaders are assigned to the 6 p.m. to 6 a.m. shift. In addition 
to loading tank cars at the VCM loading rack and the liquid caustic soda loading rack, the 
loaders may be assigned to the duties in the tank farm, to make pipeline deliveries, and to 
load trucks, barges, and seagoing vessels. Since Formosa reorganized, two loaders no 
longer are required to work together on the VCM loading rack. 



6/ The numbers and letters in the DOT classification refer to the following: ''112" (class 
designation). "A"' ''{no significance^, "340" (test pressure), and "W" (welded construction). 
7 ' J indicates that the tank car is equipped with a tank car head shield and a thermal 
protection system enclosed in a metal jacket, as required by the phase n report on 
behavior of a DOT ir2J340U" tank car in a torch fire accident. 



-7- 

A loader who was not involved in this accident told Safety Board investigators that 
before the reorganization, the two loaders assigned to the VCM loading rack would do 
maintenance work on the loading equipment, such as changing loading hoses as needed, 
changing fittings as required, and replacing broken cam arms on the quick-release 
couplings when they were broken. This loader said that since only one loader has been 
assigned to the VCM loading rack per shift, loaders have not done any preventive 
maintenance work on the loading equipment and broken equipment is repaired only as it is 
needed in the loading operation. Formosa's Manager of Administration said that an 
industrial engineering study has not been made of the total workload of the loaders, but 
that the superintendent of the loading section had evaluated the workload and determined 
that it could be handled safely. The Manager of Administration serves as Formosa's chief 
safety officer and trains employees in the proper use of air packs, respirators, safety 
glasses, and hard hats. 

At the time of the reorganization by Formosa, some employees who had no previous 
experience loading tank cars were reassigned from other duties to loading tank cars. 
Loader-2, who was on the tank car at station No. 6-2 at the time of the accident, had 
been loading tank cars for 10 months. He was trained on the job for VCM loading by 
observing other loaders. Loader-1 had 10 years' experience as a loader at the plant. 

The Safety Board's investigation determined that the most experienced loading 
employees — one with 11 years and another with 10 years — had received only on-the-job 
training for loading VCM. These two employees had instructed the less experienced and 
newly assigned employees. Employees assigned to the tank car loading operations said 
that they had never seen a written procedure for loading VCM in railroad tank cars. After 
this accident, Formosa issued a procedure. (See appendix B.) The previous owners of the 
plant. Allied and ICl, relied almost exclusively on on-the-job training for loaders and the 
use of supervisors assigned specifically to the loading area. 

The Chemical Safety Data Sheet SD-56 for Vinyl Chloride, issued by the Chemical 
Manufacturers Association (CM A) in 1972, addresses employee safety in handling VCM. 
(See appendix C.) The publication details information that supervisors and employees who 
are engaged in the loading of VCM should understand about the product and discusses the 
training they should receive. The publication gives an outline of a safety review that 
supervisors and employees of a loading facility should conduct to identify all danger points 
and recommends that the safety review be repeated periodically for aU chemical 
processing operations and always following a significant change in the process. The 
publication states that all safety precautions to be followed should be explained in 
standard operating procedures. 

Facility Information 

The plant has facilities for loading chemicals on railroad cars, tank trucks, seagoing 
barges, and pipelines. Adjoining the Formosa property are an Ethyl Corporation plant to 
the east, a Copolymer Corporation plant to the north, the Mississippi River to the west, 
and an Exxon Oil refinery to the south. 

The VCM railroad tank car loading rack facility is located in the center of the plant 
near the liquid chlorine facility. The VCM production and storage spheres are located to 
the north of the loading rack. High-pressure storage tanks and the liquid caustic soda 
railroad tank car loading rack are located to the east. An ethylene dichloride 
low-pressure storage tank is located to the west. All of these facilities are located within 
several hundred feet of the VCM loading rack and would very likely have been affected by 
a violent tank car rupture. 



-8- 
Method of Operation 

The VCM loading rack is an elevated metal walkway between two railroad tracks 
that provides easy access to the valves located in the domes atop the tank cars. On the 
loading rack are (1) the VCM liquid pipes leading from the VCM low-pressure storage 
spheres (routed through an electrical-powered pump located in the production plant), 
(2) the VCM vapor recovery pipes returning to the VCM production plant, (3) the gaseous 
nitrogen pipes returning to the liquid nitrogen cryogenic storage tanks (through a heat 
exchanger), (4) the electrical conduit that supplies lighting for nighttime loading, (5) liquid 
and vapor hoses for loading the cars, (6) water pipes, (7) ambient air sampling lines, (8) a 
small personnel shelter at the middle of the rack, and (9) a stairway to the ground at each 
end of the rack. 

A trackmobile is used to spot the empty tank cars at the loading rack with the car 
domes next to the loading stations. A ground wire is connected to the cars, the ear 
wheels are chocked, and the hand brakes are applied. A loader lowers a small walkway 
that is hinged at the loading rack for access to the tank car domes. Upon boarding the 
car, the loader opens the dome protective housing cover and latches it in an open position. 
The loader unplugs the sample valve and takes a sample of any residual VCM from the car. 
If the VCM is not contaminated, the loader connects the two liquid loading hoses from the 
loading rack with quick-connect couplers to the two liquid valve nipples of the tank car. 
The loader opens the vapor valve and two liquid valves on the tank car and returns to the 
loading rack and opens the vapor recovery valve and the supply valve. 

When all of the tank cars that are to be loaded are hooked up, the loader uses a 
radio to instruct the VCM plant operator in the plant control room to start the liquid VCM 
pump, and the VCM begins to flow into the tank car. When the gauging device indicates 
that the VCM in the tank car has reached a predetermined level near the level permitted 
by Federal regulation (49 CFR 173.314(f)(1)), the supply valve on the loading rack is 
closed. When all of the cars are loaded, the loader uses the radio to instruct the VCM 
plant operator to shut off the liquid VCM pump. Next, the loader opens the nitrogen 
valve, and the nitrogen pressure forces the residual VCM in the liquid loading hoses into 
the tank car. The loader closes the vapor valve and the liquid valve on the tank car, and 
the nitrogen pressure is vented from the liquid loading hoses into the environment. This 
action releases the pressure in the vapor hose, permitting the liquid loading hoses to be 
uncoupled from the car. 

There are no Federal regulations governing the valves, hoses, or connectors used on 
a rack facility for the loading of rail cars with a hazardous material. 

The chief safety officer for Formosa stated that the company safety program is 
administered by a safety council made up of the top plant managers. They meet each 
month to review problems and establish policy and procedures. The safety council 
chairman and the chief safety officer then meet with all of the plant supervisors to 
discuss the information that the safety council has considered that month. The 
supervisors in turn conduct safety meetings with employees throughout the plant. The 
chief safety officer further stated that there is a program to monitor the safety practices 
of employees. A designated safety manager tours the plant observing employees as they 
work to see that the job is being done correctly, that the proper tools are being used, and 
that employees use their safety gear. He stated that there were no specific safety rules 
established for individual jobs in the plant. 



-9- 

Supervisors and employees involved in this accident stated that they did not know if 
an emergency plan existed in the plant. They were not aware of any procedures they were 
to foUow in the event of an emergency, or of a specific evacuation site when an accident 
occurs. Formosa gave Safety Board investigators a copy of an emergency plan for the 
plant and advised that the plan had been in effect for many years and that top managers 
knew of the plan. 

Meteorological Information 

The temperature was 65°, winds were light and variable, and the night was clear at 
the time of the accident. 

Ignition Sources 

Investigators were unable to determine the source of ignition. The CMA Chemical 
Safety Data Sheet SD-56 states: 

Vinyl Chloride is a gas at normal atmospheric temperature and pressure. 
The gas will burn very readily in proper mixtures of air or oxygen. An 
explosion hazard can exist when draining samples or venting to the 
atmosphere. Open flames, local hot spots, friction, any spark producing 
equipment, and static electricity are to be avoided when handling this 

material. 

* * * 

All electrical equipment, motors, lights, and flashlights used in an area 
in which vinyl chloride is stored or handled should conform to the 
National Electrical Code. 

The conduit which carried the electrical lines along the loading rack was designed to 
prevent electrical sparking from reaching an explosive gaseous atmosphere and was 
termed "explosion proof;" however, investigators found that some conduit coverplates 
under the racks were missing, which exposed the wiring and negated the explosion-proof 
feature of the installation. The speaker assembly on the intercom system at the loading 
rack was neither designed nor protected to prevent electrical sparking in an explosive, 
gaseous atmosphere. A grounding cable at the track level was rusted through and did not 
provide grounding protection. The flashlights used by the loaders were not approved for 
use in a VCM handling area. Although the radios used by the loaders were authorized for 
use in hazardous locations, the batteries being used in the radios were not because they 
supplied an amount of current that exceeded the level of current that precludes thermal 
or electrical ignition of flammable gas in an explosive atmosphere. The hand tools used 
by the loaders were of a ferrous material and could produce sparking in contact with other 
metals. 

The National Fire Code 1983, Volume 15, 77-24, 4-1.2 states: 

Static is generated when liquids move in contact with other materials. 
This occurs commonly in operations such as flowing them through pipes, 
and in mixing, pouring, pumping, filtering or agitating. Under certain 
conditions, particularly with liquid hydrocarbons, static may accumulate 
in the liquid. If the accumulation is sufficient, a static spark may occur. 
If the spark occurs in the presence of a flammable vapor-air mixture, an 
ignition may result. Therefore, steps should be taken to prevent the 
simultaneous occurrence of the two conditions. 



-10- 



Emergency Responst 



Because of the carcinogenic properties of VCM and a concern that further 
explosions could occur, Louisiana State Police evacuated 250 people immediately after 
the accident from a small community on the west bank of the Mississippi River. The 
State Police notified the Coast Guard, which immediately closed the adjacent area of the 
Mississippi River to traffic. The Federal Aviation Administration (FAA) was contacted to 
restrict air traffic in the accident area. The FAA initially closed the Baton Rouge 
Airport, since the Formosa plant was located within the airport traffic area. The 
restriction was modified later to cover only the immediate area over the plant site. 

In addition to the Louisiana State Police, units from the Baton Rouge Fire 
Department, Baton Rouge City Police, and the Sheriff's office in East Baton Rouge 
responded to the accident site. Units from these organizations began to arrive at the 
accident site within 15 minutes after the fire erupted. The Baton Rouge Fire Department 
immediately positioned a ladder truck equipped with an unmanned water turret to direct 
water onto the chlorine storage tanks which were about 200 feet east of the fire. Also, 
the plant's stationary unmanned water towers were used to direct water onto the tank 
cars adjacent to the two tank cars that were on fire. The two tank cars continued to 
burn; the fire in the car at station No. 6-2 burned out by midafternoon, while the car at 
station No. 5-2 was allowed to burn at a steady but moderate rate while water was 
applied to control its temperature. 

Formosa decided to hot-tap 8/ the bottom of the burning car at station No. 5-2 and 
to try to pump the remaining VCM — approximately 13,000 gallons — into an empty tank 
car. The hot-tap was completed at noon on August 2, 1983, approximately 80 hours after 
the fire began. An attempt was made to pump the VCM, but the pumps were not capable 
of overcoming the 45-psi pressure in the receiving tank car. Formosa decided to allow a 
controlled burn-off of the tank car by placing an open container in an adjacent ditch, 
connecting the tank car and container with pipe, and igniting the VCM as it entered the 
container. Preparations for the burn-off were completed at 4 a.m., on August 4, 1983, 
about 120 hours after the fire began. The burn-off was begun immediately and was 
completed in 12 hours The air near the plant was monitored during the burn-off, and there 
was no detectable increase in air contaminants. The emergency was declared to be ended 
when the two tank cars at station Nos. 6-2 and 5-2 were filled with water. 

Medical and Pathological Information 

Loader-2 sustained first-, second-, and third-degree burns over 61 percent of his 
body. Loader-3 also received serious burns to his left side, left arm, and face. 

Survival Aspects 

Loader-2 said that he does not know how far he had run from the tank car at the 
VCM loading rack when the leaking VCM was ignited and that he does not remember 
anything after that. After hearing the explosion and seeing the fire, loader-1 returned to 
the area to search for loader-2. Loader-1 found loader-2 in a locker room, put him into a 
truck, and transported him to the first-aid station at the main gate. Most of loader-2's 
clothing was burned away or fused to his body. 

8/ ^o hoi -tap a lank car, a flange and fitting are welded to the bottom of the car and a 
hole is drilled through the tank shell. The content then can be piped from the car. 



-11- 

Loader-3, who was on the liquid caustic soda loading rack when the VCM was 
ignited, was able to get off the loading rack, remove his burning outer clothes, and make 
his way to the locker room/toolhouse area. On arriving at the locker room area, loader-3 
was met by two loading supervisors who transported him to the first-aid station at the 
main gate. 

Both injured loaders were wearing work clothes of synthetic material. Synthetic 
material can create static electricity, and when burned these materials melt and 
impregnate the skin, resulting in more severe burns. Formosa does not furnish work 
clothes and does not advise its employees about the type of clothing that is acceptable 
and safe when working around combustible chemicals. 

An emergency rescue unit driver at the neighboring Exxon plant saw the fire, and 
after notifying his plant manager drove the Exxon emergency rescue vehicle to Formosa's 
main gate. The injured loaders, accompanied by a supervisor, were transported to the 
Baton Rouge General Hospital in the Exxon vehicle. 

Tests and Research 

The quick-connect coupler from the end of the liquid loading hose at station No. 6-2 
was examined after the accident, and investigators found that one of the two cam arms 
was broken and missing from the shank. This connection, with the cam lock fitting with 
the broken cam arm, had been made when the hoses were attached to the tank car by the 
previous shift sometime before 6 p.m. on July 29, 1983. Examination of the fracture area 
revealed that there was a series of parallel gouges made by pliers on the face of the 
fracture and on the sides of the shank. The face of the fracture and the gouges were 
covered with the same degree of oxidation/corrosion as the other areas of the coupler. 

Loader-3 stated that while the loaders did not use couplers with a broken cam arm, 
it was possible to lock or unlock a cam with a broken end on the quick-connect coupler by 
using pliers. Following the accident, a channel-lock pliers was found next to the liquid 
valve connection on top of the tank car. 

Investigators conducted hydrostatic pressure tests of new and used couplers and 
gaskets of the same type to determine how the quick-connect coupler may have failed. 
The tests were conducted with a hydraulic press, a coupler mount or stand, and a coupler 
adapter fitted with a pressure gauge. The couplers were subjected to internal pressures of 
120, 300, and 1,500 psi. None of the couplers leaked or became disconnected during the 
tests. Investigators noted that regardless of the condition of the coupler, adapter, or 
gaskets being tested, the internal pressure caused the bottom edge of the adapter groove 
to push against the under edge of the cam arms, increasing the locking force. At 120 psi, 
the cam arm locking pressure was increased by a factor of 3 times ambient pressure. As 
internal pressure was increased to 1,500 psi, the adapter continued to push against the 
cam, leaving a crease or indentation in the cam arm. The coupler involved in this 
accident had no such impression or cam distortion. 

The loaders reported that incidents have occurred during loading when the liquid 
loading hose has burst and allowed a release of VCM until they could shut off the supply 
valve on the loading rock, but in those cases VCM was effectively stopped from coming 
out of the tank car bv the excess flow valves. 



-12- 
Other Information 

Excess Flow Valves. — The excess flow valves in the tank car at station No. 6-2 did 
not operate to shut off the sudden outward flow of VCM when the liquid loading hose 
became disconnected. A postaccident inspection of the tank car liquid lines by Federal 
Railroad Administration (FRA) inspectors and Formosa personnel determined that the 
seats of the two excess flow valves located in the liquid piping line inside the tank car at 
station No. 6-2 were not screwed properly into their threaded housing within the valve 
body. This discovery led to the inspection of the excess flow valves of other tank cars at 
the Formosa plant to determine if this improper valve seating was an isolated case. 
Through February 1984, 23 of the 38 tank cars inspected either by Formosa alone or 
jointly by Formosa and FRA inspectors were found to have one or more improperly 
positioned excess flow valve seats. 

Because of its concern that improperly positioned excess flow valve seats could 
allow minor railroad accidents to escalate into major threats to public safety, the Safety 
Board issued Safety Recommendations R-84-13 through -16 in March 1984 to the FRA, 
the Association of American Railroads (AAR), the CMA, and the American Short Line 
Railroad Association (ASLR) alerting them to the problem. (See Recommendations 
section on page 19.) 

As a result of these recommendations, the AAR informed its member railroads and 
shippers of the accident at the Formosa plant and the findings regarding the excess flow 
valves. The AAR also notified certified tank car repair facilities of the excess flow valve 
problems, and the AAR tank car committee began an investigation into the design and 
installation of the tank car excess flow valves. The FRA joined with the AAR in a 
comprehensive inspection program to determine the condition of the seats on excess flow 
valves. The program called for an inspection of an additional 600 to 700 cars. To 
accomplish this inspection and analysis of the facts developed during the inspection, the 
AAR established a task force. The task force has completed its work and has made a 
report of its findings to the tank car committee. The AAR is expected to issue a report 
with a corrective action plan. Both the CMA and the ASLR notified their members of the 
accident and the findings regarding the excess flow valves. 

Safety Oversight. — A Louisiana State Police hazardous materials unit spokesman 
said that a State statute authorizes the State Police to enter and inspect any facility 
handling hazardous materials. Because of limited manpower and their highway-oriented 
operation, however, the State Police inspect only vehicles on the highway or highway 
vehicles at loading racks and terminals. The spokesman said that the State Police 
recently had sent two officers to school for training in the inspection of railroad cars. 
The Louisiana State Fire Marshal's office advised investigators that, although the fire 
marshal had the jurisdiction to inspect loading facilities, the office lacked the resources, 
manpower, and expertise to inspect such facilities in a petrochemical plant. The fire 
marshal's office had no record that it had made any inspections at the Formosa plant. 

The U.S. Department of Labor, Occupational Safety and Health Administration 
(OSHA) has regulatory authority and jurisdiction to inspect the Formosa plant 
facilities. 9/ OSHA had. made inspections of the plant as follows: 

9/ An OSHA inspector typically inspects such things as electrical lines, tools, and 
equipment and sometimes arrives at a facility unannounced. 



-13- 

October 10, 1973 General Schedule Inspection 

November 27, 1973 Follow-up Inspection 

February 21, 1974 Inspection Following an Accident 

May 16, 1974 General Schedule Inspection 

Unl<nown, 1975 General Schedule Inspection 

December 10, 1976 General Schedule Inspection 

Since 1976, OSHA has established priorities to perform general schedule inspections, and 
Formosa was not scheduled by OSHA for a general schedule inspection. Currently, OSHA 
is making unscheduled inspections only as the result of an employee complaint or a 
catastrophic accident. 

Formosa has rebuilt the tank car loading rack between track Nos. 5 and 6. OSHA 
has not inspected the plant since the accident and has not examined the rebuilt rack. 
OSHA reviewed injury and iUness reports for the Formosa plant on January 31, 1985. 
Because the injury/illness rate was lower than the national average, no inspection of the 
facilities was conducted or scheduled. 

The Transportation Safety Act of 1974, Public Law 93-633, 88 Stat. 2156, 
Title I-Hazardous Materials, Section 102, states, "It is declared to be the policy of 
Congress in this title to improve the regulatory and enforcement authority of the 
Secretary of Transportation to protect the nation adequately against the risks to life and 
property which are inherent in the transportation of hazardous materials in commerce." 
The DOT'S area of responsibility is further clarified in Section 103(6): "Transport or 
transportation means any movement of property by any mode, and any loading, unloading, 
or storage incidental thereto." The FRA has a hazardous materials inspector in New 
Orleans, Louisiana, 85 miles from Baton Rouge, but the railroad loading facility at the 
Formosa plant was last inspected by an FRA inspector in 1977 following a material 
handling accident. 

OSHA and the FRA do not have an agreement of understanding for the safety 
inspections of railroad tank car loading and unloading facilities. OSHA has regulations for 
railroad tank car loading/unloading facilities, but the FRA does not. 

The Coast Guard inspects the marine loading facility at the Formosa plant annually. 
The Coast Guard and OSHA have a working agreement, and both agencies have cooperated 
in the inspection of hazardous materials stored on docks and in the investigation of 
accidents and incidents on vessels involving hazardous materials. 

ANALYSE 

The Accident 

Loader-2 said that the VCM liquid loading hose unexpectedly came loose from its 
attachment to the tank car and that the VCM from the tank car was released under 
pressure of about 120 psi. It is not likely that the loading hose became disconnected 
because of a mechanical failure. The quick-connect coupler was tested at pressures of 
120, 300, and 1,500 psi without inducing a separation of the coupler and hose. Because 
binding marks in the coupler metal, such as occurred during the test at 1,500 psi, were not 
found on the coupler used to attach the liquid loading hose to the tank car at station 
No. 6-2, the Safety Board concludes that the coupler did not come off because of pressure 
in excess of 1,500 psi. 



-14- 

Loader-1 had completed aU of the steps involved in loading the tank car at station 
No. 6-2 except using nitrogen to purge the residual VCM from the vapor hoses and the 
liquid loading hoses and disconnecting the hoses. Loader-1 told loader-2 that he had not 
finished securing for shipment the four remaining cars, including the ear at station 
No. 6-2, because of low nitrogen pressure. When he started to do the work, loader-2 
might not have recalled what steps were left to be taken before the liquid loading hoses 
were disconnected because the turnover discussion may have been too vague and did not 
convey the necessary tasks to be completed. The company did not have a formal turnover 
procedure. Loader-2 said that he was on the tank car at station No. 6-2 at the time of 
the accident. The only reason for his being on the tank car would have been to disconnect 
the hoses and to secure the dome cover. If he did not remember that the loading hoses 
had not been purged with nitrogen and therefore released the locking cams on the 
quick-connect coupler, the connection would have separated immediately. With 120-psi 
pressure on the hose, it would have been impossible to reconnect the hose. 

The oxidation/corrosion on the fractured surface of the cam arm being the same as 
on other areas of the coupler indicates that the missing shank was broken off before the 
accident. Therefore, since the hoses were connected to the tank cars on the previous 
shift, prior to 6 p.m. on July 29, 1983, the broken cam arm on the quick-connect coupler 
was not changed but was used to make the connection at least 10 hours before the 
accident occurred. The channel-lock pliers found on top of the tank car at station 
No. 6-2 next to the tank car connections suggest that loader-2 used the pliers to release 
the broken cam arm on the coupler and then laid them down while engaged in releasing 
the other cam arm by hand. The gouge marks on the broken surface of the cam arm could 
have been made by the pliers found on the tank car if they had been used to grip the cam 
arm to release it. 

After the accident the tank cars at station Nos. 5-1 and 6-1 were found secured for 
shipment. Since loader-1 said that they were not secured when he left the loading rack, 
the Safety Board concludes that either loader-1 or loader-2 closed the liquid valves, and 
loader-2 completed securing the tank cars for shipment. The investigation did not 
determine if the nitrogen pressure came up to a level that allowed the hoses on those tank 
cars to be purged or whether the liquid loading hoses were released without purging. It is 
possible that the excess flow valves in the tank cars may have activated if the 
quick-connect couplers were removed before the liquid valves had been closed. If so, the 
VCM under pressure would not have sprayed from the tank car's liquid valve nipples, but 
the residual VCM in the liquid loading hoses would have spilled. 

A cam -lock, quick-connect coupler is joined together when one half of the fitting is 
pushed onto the other half and held in place by the cam arm being forced closed, causing 
the cam section to engage only a grooved section of the other fitting. Therefore, a 
quick-connect coupler will disengage immediately if released under pressure. Because it 
cannot be reconnected easily, it should not be used on hoses and connections used to load 
or unload hazardous materials. However, there are no regulations that prohibit their use, 
and many chemical firms use them because that they are a labor-saving device. Other 
couplers are available that cannot be released while the connection is under pressure. The 
Safety Board believes that the use of quick-connect couplers should be prohibited in the 
transfer of hazardous materials and that the DOT should review the types of appliances 
used on hazardous materials loading racks and establish standards for the types of 
couplers that may be used. Since the accident, the Formosa plant has changed the type of 
rack hose couplers being used so that if the liquid loading hose is under pressure, the 
coupler will leak before it is fully disengaged and alert the loader so he can retighten the 
coupler quickly. 



-15- 
Excess Flow Valveg 

Neither of the two excess flow valves within the tank car at station No. 6-2 was 
screwed properly into its threaded valve housing. The excess flow valve in the tank car's 
internal liquid line that was attached to the loading hose that was disconnected did not 
operate to shut off the outward flow of VCM from the car when the loading hose was 
disconnected. It is possible that the loader may have been able to hold the hose for a 
short period of time after disconnecting the coupler and tried to force the hose back onto 
the connection. This action would have provided a sufficient restriction to the flow of 
VCM to prevent a sudden surge and, therefore, even a properly seated excess flow valve 
would not have activated to shut off the flow. However, with the excess flow valve 
improperly seated, the flow would not have been shut off regardless of the circumstances 
under which the hose was disconnected. 

Shippers and receivers as a matter of routine rely upon the proper functioning of the 
excess flow valve to protect against the inadvertent outward flow of hazardous materials 
from tank cars during loading and unloading operations. There have been incidents of 
loading hoses bursting during the loading process in which the excess flow valves 
prevented the discharge of a large volume of material. Had the excess flow valves on the 
tank car in this accident been seated properly, the accident probably would not have 
occurred. However, excess flow valves are not installed on cars for the purpose of 
providing protection during the loading/unloading of hazardous materials, and shippers and 
receivers should not rely on the valve to provide protection to the exclusion of proper 
safeguards. A properly functioning excess flow valve is designed to and can prevent minor 
railroad accidents from escalating into major threats to public safety by the uncontrolled 
release of product when there is damage to or severing of external valves in the course of 
an accident. 

Both the AAR and the FRA responded to Safety Board Recommendations R-84-13 
through -15 regarding excess flow valves and have coordinated to conduct an investigation 
that soon should result in corrective action. The Safety Board is pleased that the FRA 
and AAR have taken prompt action to address the serious hazard presented by improperly 
installed excess flow valves. 

Ignition Sources 

Investigators could not determine which of the many possible sources of ignition 
started the fire. The unrestricted flow of VCM through the hose could have involved 
sufficient static electricity in the flammable vapor-air mixture to have caused ignition. 
A spark in the exposed wiring under the loading rack or in the speaker wiring and 
connections of the intercom could have caused ignition. The radios used by the loaders 
could have caused thermal or electrical ignition. A handtool in the area could have 
caused sparks while in use, or if dropped on the tank car shell, manway cover, valves, or 
fittings. 

Because of the hazards involved in handling VCM, the need to review continually the 
safety of the operating equipment and facilities is critical. The presence of so many 
unsafe conditions which did not conform to the requirements of the National Electrical 
and Fire Codes indicates that Formosa management and supervisory personnel had allowed 
unsafe conditions to develop unchecked. A proper safety inspection by responsible 
management would have detected the unprotected wiring, the installation of a speaker 
assembly in the intercom system that was not spark-proof, and the use of flashlights and 
of batteries in radios that were unsafe for use in the VCM environment at the loading 
rack. 



-16- 
Training and Supervision 

The CMA Chemical Safety Data Sheet SD-56 recommends intensive training of 
employees and supervisors involved in the handling: of VCM; however, following^ the 
reorganization of the operation of the Formosa plant and a change in ownership, the only 
training given to employees and supervisors was on-the-job training. While this training 
can prepare employees to carry out their jobs effectively, it also leads to senior 
employees who have acquired poor work habits, despite their many years of experience, 
passing on these habits. Although supervisors engaged in handling VCM must be familiar 
with the hazardous characteristics of the product and how to handle it, the new 
supervisors, who had learned loading procedures only by observing the senior employees as 
they performed their duties, would not have recognized the poor work habits. Nor would 
the supervisors conduct any inspection that would disclose that the equipment at the 
loading rack was unsafe, because all of it was in place at the time of the reorganization 
when they were assigned as supervisors. Provisions should have been made for refining 
on-the-job training with particularized instruction on equipment and good safety 
practices. 

Moreover, there were no written procedures at Formosa for loading VCM. The 
Safety Board believes that had Formosa management provided detailed operating 
instructions and training to those employees involved in loading VCM, loader-2 might have 
been more cognizant of the hazardous characteristics of VCM and might have made a 
more cautious inspection before proceeding to disconnect the loading hose. 

Safety Oversight 

The Formosa safety inspection program not only did not detect the generally unsafe 
working conditions that existed at the rail ear loading racks but also did not result in the 
detection of defective loading equipment. Since safety inspections were not performed by 
Federal or State agencies, the fact that safety was not being addressed in an appropriate 
manner by Formosa went undetected. 

The safety of petrochemical plant operations is only as good as each individual 
plant's safety program. While large-scale accidents may occur infrequently, they can 
cause large amounts of property damage, injuries, and social disruption. Toxic and/or 
flammable concentrations of chemicals can impact population exposures surrounding a 
petrochemical plant within minutes of the initial release. 10/ The potential for 
catastrophic accidents in an area such as Baton Rouge and surrounding communities with 
their extremely dense concentration of petrochemical plants is extremely high. If a 
BLEVE (a Boiling Liquid Expanding Vapor Explosion) had occurred in the accident, the 
explosion could have resulted in a chain-reaction of explosions throughout the Formosa 
plant and affected adjacent plants, escalating the accident to a catastrophe. Effective 
safety oversight is critical, and Federal and State agencies that have the responsibility 
and the authority to enforce safety standards in petrochemical plants should reevaluate 
their priorities in scheduling inspections and training inspectors to insure that a high level 
of safety is maintained at these chemical plants. The Safety Board believes that 
insufficient Federal and State oversight contributed to the lack of safety procedures, 
inadequate training of personnel, and poor maintenance of loading rack equipment at the 
Formosa plant. 



10 / The Safety Board discussed the issue of emergency preparedness plans for fixed-site 
hazardous materials handling facilities in its Special Investigation Report~"Railroad Yard 
Safety: Hazardous Materials and Emergency Preparedness" (NTSB/SIR-85/02). 



-17- 

The Safety Board believes that employees and supervisors should be trained in 
emergency procedures. Even if Formosa's emergency plan is that most of its employees 
will evacuate to a designated location, this information should be a part of an emergency 
preparedness plan and should be made known to everyone in the plant. The emergency 
response cadre should be trained in depth. 

Tank Car Safeguards 

This accident demonstrated that the safeguards required by 49 CFR Parts 173 and 
178 are effective in reducing the severity of hazardous materials accidents involving tank 
cars equipped with those safeguards. Even though the tank car at station No. 5-2 was 
exposed to severe fire torching, it did not rupture. Since pressure sufficient to open the 
safety valve did not build up until 50 to 60 minutes had elapsed, it is apparent that the 
Korotherm insulation and the steel jacket performed as intended to delay the heating, 
expansion, and vaporization of the VCM. Loader-2 and loader-3 had time to escape the 
area long before the safety valve was released, and emergency response personnel had 
time to act to mitigate the results of the fire. 

As a result of its investigations of numerous railroad tank car accidents between 
1968 and 1979, the Safety Board identified several tank car safety problems and 
recommended Federal action to improve tank car safety and to reduce the danger to the 
public from derailments of tank cars carrying hazardous materials. The Board held a 
public hearing in April 1978 on the derailments of tank cars carrying hazardous 
materials. U/ As a result of the hearing, the Safety Board issued Safety 
Recommendations R-78-9 through -36 on April 24, 1978, recommending that the FRA 
accelerate Federal rulemaking actions to require the installation of head shields, shelf 
couplers, and thermal protection on tank cars carrying volatile products. The Safety 
Board has repeatedly urged the implementation of these recommendations because it was 
convinced that these safeguards would provide the protection needed. 

FRA rulemaking (Docket No. HM-144) followed and required that all new and 
existing DOT specification 112 A (114 A) tank cars carrying flammable gases be equipped 
with a thermal protection system meeting certain performance standards for both torch 
and pool fires. The retrofit program was carried out from 1978 through 1980. The tank 
car at station No. 5-2 was retrofitted with the safeguards in 1980. This accident 
demonstrates that equipping tank cars with thermal protection should lead to a dramatic 
reduction in the number of violent ruptures not only in train derailments but also in train 
yard and chemical plant accidents. 

A joint Railway Progress Institute (RPI) and AAR Tank Car Safety Project group 
conducted extensive evaluations of the tank car at station No. 5-2 after the accident. In 
a report issued on January 21, 1985, 12/ the group stated, "Had it not been equipped with 
HM-144 thermal shielding, it quite probably would have ruptured violently." The Safety 
Board is pleased that the extensive testing done by the RPI-AAR has corroborated the 
benefits of thermal problems of tank cars. 

TT7~Safefy~^ffectTveness Evaluation— "Analysis of Proceedings of the National 

Transportation Safetv Board into Derailments and Hazardous Materials, April 4-6, 1978" 

(NTSB-SEE-78-2). 

12/ Phase II Report on Behavior of a DOT 112J340W Tank Car in a Torch Fire Accident. 



CONCLUSIONS 



Findings 



1. The vinyl chloride monomer (VCM) liquid loading- hose to the tank car at 
station No. 6-2 probably was disconnected by loader-2 before the loading hose 
was purged of VCM. 

2. The excess flow valves in the tank car did not activate to stop the flow of 
VCM because they were not seated properly. 

3. Sources of ignition of the VCM included exposed electrical wiring on the 
loading rack which could have caused sparks, the speaker assembly on the 
intercom system which was not designed or protected to prevent electrical 
sparks, the ferrous metal tools used on the unloading rack which could have 
caused sparks, and/or the portable radios used by the loaders which had 
batteries that were not approved for use in a flammable or explosive 
atmosphere which could have caused sparks. 

4. Loading employees of the Formosa Plastics Corporation were not trained 
adequately in safety procedures related to loading operations at the rail 
loading racks. 

5. The Formosa Plastics Corporation did not have written procedures or a safety 
program for supervisors and employees involved in the loading of VCM. 

6. The unsafe working conditions at the VCM loading rack were not detected and 
corrected by the plant's safety inspection program. 

7. No State of Louisiana agency had inspected the Formosa Plastics Corporation 
plant for compliance with State safety regulations before the accident. 

8. Federal regulations concerning working conditions and the equipment in use at 
the VCM loading rack were not being enforced in the plant because the 
Federal Railroad Administration had not inspected the plant since 1977, and 
the Occupational Safety and Health Administration had not inspected the plant 
since 1976. 

9. Tank car safeguards retrofitted to the tank car at station No. 5-2 prevented 
the tank car from rupturing violently in the fire and possibly causing a more 
catastrophic accident. 

Probable Cause 

The National Transportation Safety Board determines that the probable cause of the 
sudden release and ignition of vinyl chloride monomer from a loaded tank car was a plant 
employee's failure to close the tank car liquid valves and purge the pressurized vapor 
return and loading hoses before disconnecting them, and the presence of one or more 
sources of ignition at the loading rack. Contributing to the cause of the accident was the 
failure of the Formosa Plastics Corporation to maintain safe facilities for the loading of 
vinyl chloride monomer and to provide written procedures, adequate training, and 
supervision for its loading personnel. Also contributing to the cause of the accident were 
the improperly seated excess flow valves in the tank car. 



-19- 

RECOMMENDATIONS 

During its investigation of this accident, the National Transportation Safety Board 
issued the following recommendations in March 1984: 

— to the Association of American Railroads: 

Immediately advise member railroads, shippers, and receivers that 
handle hazardous materials in tank cars of the accident at Baton Rouge, 
Louisiana, on July 30, 1983, and of the subsequent findings regarding 
improperly positioned excess flow valve seats, and alert them not to rely 
upon tank car excess flow valves for protection against an undesired 
outward flow of hazardous materials from tank cars during loading, 
unloading, maintenance, or repair operations. (R-84-13) 

Immediately issue a service bulletin to all Association of American 
Railroads-certified facilities emphasizing the need to verify the proper 
installation, maintenance, and testing of excess flow valves on tank cars. 
(R-84-14) 

— to the Federal Railroad Administration: 

Immediately initiate inspections of tank cars equipped with excess flow 
valves to determine the extent to which these tank cars may have 
improperly positioned excess flow valve seats, determine the cause of 
deficient conditions found, and require correction of deficiencies before 
inspected tank cars are returned to service. (R-84-15) 

— to the Chemical Manufacturers Association: 

Immediately advise its members of the hazardous materials accident at 
Baton Rouge, Louisiana, on July 30, 1983, and of the subsequent findings 
regarding improperly positioned excess flow valve seats, and alert them 
not to rely upon tank car excess flow valves for protection against an 
undesired outward flow of hazardous materials from tank cars during 
loading, unloading, maintenance, or repair operations. {R-84-16) 

— to the American Short Line Railroad Association: 

Immediately advise its members of the hazardous materials accident at 
Baton Rouge, Louisiana, on July 30, 1983, and of the subsequent findings 
regarding improperly positioned excess flow valve seats, and alert them 
not to rely upon tank car excess flow valves for protection against an 
undesired outward flow of hazardous materials from tank cars during 
loading, unloading, maintenance, or repair operations. (R-84-16) 



-20- 

As a result of its complete investigation of this accident, the National 
Transportation Safety Board made the following recommendations: 

— to the Formosa Plastics Corporation: 

Establish a training program and loading turnover procedures for 
supervisors and employees assigned to load hazardous materials for 
transportation. (Class II, Priority Action) (R-85-65) 

Establish a safety inspection program to detect and correct any 
conditions at the plant that do not meet requirements of the National 
Electrical and Fire Codes and regulations of the U.S. Department of 
Transportation. (Class n. Priority Action) (R-85-66) 

In cooperation with the city of Baton Rouge, Louisiana, establish an 
emergency preparedness plan and evacuation procedures for employees 
in the event of a leak or fire at the plant involving hazardous materials. 
(Class II, Priority Action) (R-85-67) 

— to the Federal Railroad Administration: 

Establish a program to inspect rail loading facilities at petrochemical 
plants on a regular schedule. (Class II, Priority Action) (R-85-68) 

Develop a memorandum of understanding with the Occupational Safety 
and Health Administration to define the extent of each agency's 
responsibility for safety inspections of hazardous materials 
loading/unloading facilities at petrochemical plants to eliminate gaps or 
overlaps in responsibility. (Class II, Priority Action) (R-85-69) 

— to the Research and Special Programs Administration: 

Establish safety standards and inspection procedures for loading 
facilities at petrochemical plants. (Class II, Priority Action) (R-85-70) 

— to the Occupational Safety and Health Administration: 

Evaluate its ability to conduct inspections of petrochemical plant loading 
facilities and its method of establishing inspection priorities for general 
schedule inspections, and make necessary changes to provide for regular 
inspections. (Class II, Priority Action) (R-85-71) 

Develop a memorandum of understanding with the Federal Railroad 
Administration to define the extent of each agency's responsibility for 
safety inspections of hazardous materials loading/unloading facilities at 
petrochemical plants to eliminate gaps or overlaps in responsibility. 
(Class II, Priority Action) (R-85-72) 

—to the State of Louisiana: 

Evaluate the ability of State agencies charged with administering safety 
regulations in petrochemical plants to carry out their responsibility, and 
make necessary changes to insure regular inspections of these facilities. 
(Class II, Priority Action) (R-85-73) 



-21- 
BY THE NATIONAL TRANSPORTATION SAFETY BOARD 

/s/ JIM BURNETT 
Chairman 

Is/ PATRICIA A. GOLDMAN 
Vice Chairman 

/s/ G. H. PATRICK BURSLEY 
Member 

Mav 1-4, 1985 



-23- 

APPENDIXES 

APPENDIX A 

INVESTIGATION 

1. Investigation 

The National Transportation Safety Board was notified of the accident at 7 a.m., on 
July 30, 1983. The Safety Board immediately dispatched investigators from Washington, 
D.C., to the accident site. 

Groups were formed to investigate the hazardous material release, mechanical 
factors, and survival factors. The Safety Board was assisted in its investigation by 
representatives of the parties: the Formosa Plastics Corporation, the Federal Railroad 
Administration, the U.S. Department of Labor, and the Louisiana State Police (Hazardous 
Materials Unit). 



-24- 

APPENDIX B 

FORMOSA PROCEDURE FOR LOADING 
VINYL CHLORIDE TANK CARS 
(ISSUED AFTER JULY 30, 1983) 

1) Spot cars at tank car loading stations so that ramps are in proper position. 

2) Double, diagonally, chock cars (A chocks per car), and set all hand brakes. 
The double diagonal chocking results from reports that, while loading, some 
cars have jumped over a single chock and started rolling while still hooked 
up. 

3) Set derails and car-connscted 'flags' on tracks where cars are to be loaded 
north of south road to vinyl plant. 

Note: There is to be no switching permitted south of the south road to vinyl 
plant while the red loading light is on and vinyl cars are hooked up. 

k) Inspect car. Open dome of car. Remove valve plugs. Use caution. If valves 
leaked, there could be pressure behind them. Remove gauge rod cover. Again, 
watch for a possible pressure build-up under the cover. Fill out pre-loading 
inspection sheet, and switch T/C placards for loading. 

5) Check each car for ppm O2 from vapor valve on car. Use special 2" x 1/A" 
reducer and valve to connect 0^ meter. 

a) The maximum allowable O2 for loading Is 1000 ppm. 100-500 ppm is ideal. 
If below 1000 ppm 0„ proceed to Step 6. 

b) If Oy is greater than 1000 ppm refer to T/C purging instructions at end 
of triis procedure write-up. 

6) Open emergency shut-off load line valve. This valve should be closed when 
not loading vinyl Emergency trip buttons which will close this valve and 
shut down the vinyl pump are located: 

a) At the head of the stairs at the temporary loading station. 

b) In the vinyl control room. 

c) At the head of the north stairs at the main loading rack and between 
Nos. 3 and k loading stations on the main loading rack. 

7) Turn on red flashing vinyl loading light. Switches are located at both the 
temporary and main loading stations. 

8) Check to see if the intercom between loading rack and vinyl control room is 
functioning. 



-25- 



9) Check to be sure you have radio communication with vinyl and your foreman. 

10) If nitrogen pressure is low notify your foreman and the vinyl foreman. 

11) Connect grounding cables. 

12) Use only non-sparking tools, flashlights, and radios. Tools should be made 
of beryl ium or aluminum with recessed steel jaws. The flashlight is the 
Eveready No. 1259. For radios this means a green battery. 

13) Hook up tank car to loading rack. 

a) Screw 2" nipples, with check valves, into T/C liquid valves. Check action 
of check valves before installing nipples. 

b) Screw 2" nipple into T/C vent valve. This nipple has a ]-]/k" connector 
at other end. 

c) Hook 2 - 2" loading hoses and one 1-1/A" vent hose to these nipples using 
the knock-on type connectors. 

Note: All piping must be wrench tight. 

\k) Once all cars to be loaded are hooked up and ready for loading, pressure test 
the two loading hoses with nitrogen. 

15) Open vent valves on cars. If T/C pressure is 6O-9O psig, vent it down to 
50 psig to recovery system before starting to load, (if you have the time). 
Otherwise start venting upon loading even at pressures above 50 psig. 

16) Insert Farenhelt thermometer in thermo-well on T/C to get a starting tempera- 
ture. Using this information check loading charts to get an idea of each car's 
load-out level. 

a) While loading, when gauge rod starts to move upward, check the temperature 
again to determine a correct load-out level. 

b) Record this information on loading sheet. 

17) Have vinyl put on loading pump. Open T/C loading valves. Open 3" load line 
valves. Watch load line and vent pressure gauges. Start venting when the 
pressure reaches 60 psig. 

18) Once cars have been loading for approximately 1/2 hour catch a load line sample 
and have it taken to the lab to analyze as soon as possible. Once they gee 

it Into the gas chromatograph it takes about 27 minutes to get a complete 
analysis. 

Always record time taken on all samples on the sample label. 



APPENDIX B -26- 



19) If you are having trouble vyith the vent recovery system, ask vinyl foreman to 
check it out, especially the vents condenser. If working properly, lines should 
be sweating. 

20) Once a car is loaded (when level rod reaches proper outage) close 3" load lines. 

a) Check to be sure Nj pressure is greater than T/C pressure and purge load 
lines to T/C using N_ between one and two minutes each. 

b) Close both T/C loading valves. 

c) Bleed pressure off hoses. Check pressure gauge. 

d) Disconnect load lines carefully making sure no pressure remains in hose. 

e) Similarly close T/C vent valve. Purge vinyl out of vent hose by blowing 
with N2 for one to two minutes to vent recovery system. Close 3" vent valve. 
Then vent nitrogen pressure off hose and disconnect hose carefully from T/C. 

21)- Once cars have been loaded, catch a sample from each car from the sample cock. 
If unable to catch one there, see (b) below. 

a) When catching a sample: 

(1) Connect bomb to car and low pressure vent system hose. 

(2) Open sample cock valve to bomb. 

(3) Open valve on bomb nearest sample cock. 

(k) Open valve on bomb nearest low pressure vent line. 

(5) Let product flow through bomb long enough to be sure a good clean sample 
has been obtained. 

(6) Close va've on bomb nearest low pressure vent line. 

(7) Close sample lock and valve on other end of bomb. 

(8) Disconnect low pressure hose and vent pressure off between bomb and 
sample valve. 

(9) Remove bomb. 

(10) Take samples to the lab as soon as possible. 

b) If sample line is plugged: 

(1) Try blowing it clear using N_. 

(2) If it clears catch a sample following the procedure in (a) above. 

(3) If line remains plugged, fill out a sample label with time, T/C No. and 
note that sample line is plugged and that lab should use the load line 
analysis. Also note that sample line is plugged on T/C loading sheet. 

22) Insert all plugs and caps: 

1 - Vent valve plug 

2 - Loading valve plugs 

I - Thermometer well cap 
I - Level gauge rod cap 
I - Sample 1 i ne pi ug 
All wrench tight. 



-27- APPENDIX B 

23) Close lid and seal car. Record seal number on loading sheet. 

2^) Fill out loading sheet as required. Attach it to the inspection sheet. 
Place them in folder for Traffic Department. 

25) Loeded cars are to be weighed and set on outbound storage tracl<s for shipping. 

f) All of the vinyl tank cars in our service require an average 261,000/' 
gross weight minimum. 

b) Some cars can go into the 262,000# range but none can go over 
263.OOO/T. 263,000# is the maximum gross weight we can ship. 



NOTE: 



(1) If eny problems or questions arise with equipment or procedures 
notify your foreman. 

(2) Do not permit vinyl to vent to atmosphere. Very small quantities are 
permitted as when disconnecting sample bombs. 

(3) Sonteone must be on the rack at all times when cars are connected. 

C*) Once loading has been suspended for any reason, unhook cars. This, of 
course, does not apply to brief interruptions. 

(5) In the event of an electrical storm, shut loading operation down and 
disconnect tank cars. 

(6) Follow all plant operating procedures and safety procedures. Do not 
cut corners. 

(7) Whenever one operator relieves another, for any reason, they must 
exchange all pertinent information, fill out a check list for transfer 
of responsibility and both sign it. Turn these in with other inspection 
forms and datij sheets. 



APPENDIX B -28- 



TANK CAR PURGING INSTRUCTIONS 

1) If ppm O2 Is greater than 1000 but less than 10,000 ppm, purge car to vent 
recovery until less than 1000 ppm. 

a) Using N-, build T/C pressure to 8O-9O psig. 

b) Contact vinyl and vent car down to about 60 psig to their 100# vent 
system. 

c) Then have vinyl switch to their 50# vent system and vent car down 
to about kS ps ig. 

d) (1) If 0- was originally between 1000 ppm and 1500 ppm, retest. 

(2) If 0- was originally higher than 1500 ppm, repeat steps (a), (b) and (c) 
once or twice more before rechecking. 

(3) Continue this procedure until 0_ is less than 1000 ppm. Then car 
can be loaded. 

2) ' ^ ^2 '^ greater than 10,000 ppm, notify vinyl foreman that car must be purged 
to the flare. He must OK this. 

a) Using N_ , build T/C pressure to about 80 psig. Then vent it to the flare 
until the pressure drops to about 15 ps'g. Do not vent down too fast. 

b) Repeat Step (a) twice more and then recheck the 0« level. 

c) If less than 1000 ppm, car is good to load. If not repeat Step (a) 
above until 0. level drops below 1000 ppm. 

NOTE: Never purge a car which has 10,000 ppm or more 0_ to the recovery system. 



-29- APPENDIX B 

PERMISSIBLE VENTING 
VCM LOADING 



A) Oj checking line: I" pipe IV long (vapor) 

Volume = 1" X \" X }.]k z k X iV - 11 Cu.inch = O.OO636 Cu.Ft. 

B) Sample bomb line I/'*" pipe 10" long (Liquid) 

Volume = ]/k" X l/V x 3- I'* t ^J x 10" long x 0. 00^33 gal/cu.in. x 7-5 lb/gal 
- 0.0159 lb. T 62. i< lb/lb. mole x 359 cu. ft. /lb. /mole 
■ 0.092 cu.ft. 

C) VCM loading line 2" hose £ pipe 20 ft. (vapor) 
Volume under 100 psig pressure 

« 2" X 2" X i.]k 4 A X 20 ft. 7 ]kk ft.^/in.^ = 0.i»36 cu.ft. 
2% VCM 
Volume under 100 psig pressure 

» O.A36 X 0.02 = 0.00872 cu.ft. 

(100 + IA.7) X 0.00872 = IA.7 X Volume at Atmosphere 
Volume, at atmosphere = O.O68 cu.ft. 

The regulation of VCM loading or unloading line that are to be opened to the 
atmosphere should contain no greater than 0.13 cu.ft. of VCM at standard 
temperature and pressure. 
So, the above numbers are all less than the regulation limit. 



-30- 

APPENDIX C 

CHEMICAL SAFETY DATA SHEET SD-56— 

PROPERTIES AND ESSENTIAL INFORMATION FOR 

SAFE HANDLING AND USE OF VINYL CHLORIDE 



Cl:>emical Safety Data Sheet SD-56 

PROPERTIES AND ESSENTIAL INFORMATION 

FOR 

SAFE HANDLING AND USE 

OF 

VINYL CHLORIDE 



Chemicoli in any form con b« laftly ilortd, handUd or UMd if 
the phyiical, chemicol and haiordoui proptrtiti ar« fully und»r- 
itood ond the neceiiory precoutioni, including the UM of proper 
tofeguordt and pertonal protective equipment, are obterved. 



REVISED 1972 



MANUFACTURING CHEMISTS ASSOCIATION 

1825 CONNECTICUT AVENUE, N. W WASHINGTON, D. C. 20009 



-31- 

APPENDIX C 



TABLE OF CONTENTS 

Page 

Prefoce 4 

1. NAMES 5 

2. PROPERTIES 5 

3. HAZARDS 

3.1 Health Hazards 6 

3.2 Fire and Explosion Hazards 6 

3.3 Stability Hazards 6 

4. ENGINEERING CONTROL OF HAZARDS 

4.1 Building Design 6 

4.2 Equipment Design 7 

4.3 Ventilation 7 

4.4 Air Analysis 7 

4.5 Electrical Equipment 8 

5. EMPLOYEE SAFETY 

5.1 Employee Education and Training 8 

5.2 Personal Protective Equipment 8 

6. FIRE FIGHTING 10 

7. SHIPPING, LABELING, HANDLING AND STORAGE 

7.1 Shipping 10 

7.2 Labeling 10 

7.3 Cylinders 12 

7.4 Tank Cars 12 

7.5 Transportation Emergencies 13 

7.6 Storage 15 

7.7 Repackaging 15 

8. TANK AND EQUIPMENT CLEANING AND REPAIRS 16 

9. WASTE DISPOSAL 17 

10. MEDICAL MANAGEMENT 

10.1 Health Hazards 17 

10.2 Preventive Measures 17 

10.3 Suggestions to Physicians 18 

11. FIRST AID 18 



APPENDIX C -32- 

Clpemkal Safety Data Sheet 

VINYL CHLORIDE 

PREFACE 

Vinyl chloride monomer is classified by the U.S. Department of 
Transportation as a flammable compressed gas. It is easily ignited, 
producing hazardous combustion gases largely composed of hydrogen 
chloride and carbon monoxide. 

The primary health hazard of VCM is associated with excessive 
respiratory exposure. In acute overexposures the primary effect is 
on the central nervous system, producing intoxication and dulling of 
visual and auditory responses. Excessive chronic exposure may pro- 
duce liver injury. 

The full text of this chemical safety data sheet should be consulted 
for details of the hazards of vinyl chloride monomer and suggestions 
for their control. 

FIRST AID -SEE PAGE 18 



For assistance in the event of any emergency involving this chemical in 
transportation, call MCA's Chemical Transportation Emergency Center. 

CHEMTREC 

(800) 424-9300* (Use 483-761 6 in DisUkl of Columbia) 
Toll-free, day or night 

* Uu long dittonci acccH number if r«quir*d. 

In CANADA, call Canadian Chemical Producers Association's TEAP 
(Transportation Emergency Assistance Plan) 



-33- 

APPENDIX C 



Chemical Safety Data Sheet 

VINYL CHLORIDE 



1 


. NAMES 


Chemical Names. 


Vinyl Chloride Monomer 

Chloroethylene 

Chloroelhcne 


Common Name: 


Vinyl Chloride, VCM 


Formula: 


CH2CHCI 



2. PROPERTIES 

2.1 GRADE: Commercial, sometimes referred to as Technical 

2.2 IMPORTANT PinsiCAL AND CHEMICAL PROPERTIES : 

Boiling Point at 1 atm _ — 13.8X. ( ^ 7°F.) 

Color _ Colorless or water white 

Corros!vity_ ___..Noncorrosive at normal atmospheric temperatures when 

dry (moisture free). In contact with water at elevated 
temperatures vinyl chloride accelerates corrosion of iron 
or steel. 
Explosive Limits (Percent by Volume in Air) Lower 3.6% ; upper. 26.4% 

Flash Point (Open Cup) _ — 78=C. (— 108. 4'F.) 

Hygroscopicity No 

Critical Pressure, psia ....775 

Critical Temperature ]58.4=C. (317°F.) 

Ignition Temperature, Autogenous 472.22°C. (882°F.) 

Light Sensitivity Uninhibited VCM is light sensitive 

Melting Point at 1 atm — 153.71 °C. (— 245°F.) 

(Freezing Point) 

Molecular Weight _...62.50 

Odor Sweet smelling gas. Inhibited VCM may have faint 

phenolic odor. 

Physical State Gas at ordinary temperature and pressure. Liquid under 

pressure in cylinder or pressure vessel at room tem- 
perature 

Reactivity Polymerizes readily in presence of air, sunlight, oxygen 

or heat. This behavior is due to the presence of a dou- 
ble bond. Otherwise vinyl chloride is quite stable. 
Specific Gravity of liquid @ 4°C. 

(Water = 1) 0.9121 

Vapor Density of gas (Air = 1) 2,15 

Vapor Pressure (g 68°F 35 psig 

-Density, liquid, Ib./cu. ft. 

at 70°F. 56.71 

at 105°F 54.38 

at n5°¥ 53.69 

at 130°F 52.61 

Threshold Limit Value (ceiling) SOOppm or 1300mg/M' 



APPENDIX C 



-34- 



Manuiaciuring Chemists Associofion 



Vinyl Chloride 



HAZARDS 



3.1 HEALTH HAZARDS (Sl-c Section 10 MEDI- 
CAL MANAGEMENT) 

3.;.! The primary hazard of vinyl chloride is 
associated with excessive respiratory exposure. Ex- 
posure to high levels may produce some lung 
irritation Chronic overexposure may produce Iner 
injury. When mhaled it acts primanly as an anes- 
thetic. The odor is pleasant to most individuals and. 
therefore, acutely dangerous levels ma\ be easily 
tolerated 

3.1.2 Naming Properties 

The lowest concentration of VCM at which its 
odor can be detected is reported to be 260 ppm. 
Olfactory fatigue, however, may occur and the sense 
of smell cannot be relied upon as a warning for ex- 
cessive low grade exposures. 

3.2 FIRE AND EXPLOSION H.AZARDS 

3.2.1 Vinyl chloride is a gas at normal atmos- 
pheric temperature and pressure The gas will burn 
very readily m proper mixtures of air or oxygen. An 
explosion hazard can exist when drawing samples or 
venting to the atmosphere Open flames, local hot 
spots, friction, any spark producing equipment, and 
static electricit) are to be avoided when handling this 
material. 

3.2.2 Comhuslion Products of Vinyl Chloride 
Monomer 

Analysis of a combustion gas sample obtained 
immediately above a flame of vinyl chloride monomer 
burning in air shows presence of hydrogen chloride 
(27.000 ppm). carbon dioxide (58,000 ppm), car- 
bon monoxide (9,500 ppm) and phosgene less than 



10 ppm. Only in the very near vicinity of a VCM 
fire would significant amounts of phosgene be present. 
The main sources of danger to personnel result 
from the massive formation of hydrogen chloride ga'- 
and from carbon monoxide However, the pungent 
odor of hydrogen chloride acts as a warning to clear 
the area or to obtain the necessary breathing ap- 
paratus before attempting anv fire control measures. 
See MCA Chemical Safety Data Sheet. SD-3?i Hv- 
drochloric Acid (Aqueous) and Hydrogen Chloride 
(Anhydrous). 

3.3 STABILITY HAZARDS 

Vinyl chloride is shipped and used in both the in- 
hibited and uninhibited state. In the uninhibited 
slate, high purity must be maintained since contami- 
nants may catalyze polymerization or cause decom- 
position of the VCM, liberating hydrogen chloride 
Prior to shipment, uninhibited VCM should be tested 
for stability under shipping and storage conditions. 
Cleanliness of shipping containers is of prime im- 
portance when shipping uninhibited VCM. 

Vinyl chloride may polymerize as a result of ex- 
posure to air, oxygen or sunlight at ambient or higher 
temperatures. 

Vinyl chloride does not form peroxides by autoxi- 
dation as readiK as many other monomers. 

In the absence of an initiator, VCM is chemically 
quite stable. Commercial VCM. uninhibited, is stored 
and shipped in steel containers under conditions 
which avoid exposure to air and sunlight. For large 
volume, long term storage, refrigeration is sometimes 
employed to maintain the temperature at about 20' 
C, maximum, to minimize the formation of haze, 
a condition caused by a small degree of polymeriza- 
tion 



4. ENGINEERING CONTROL OF HAZARDS 



4.1 BUILDING DESIGN 

Equipment and vessels containing VCM should 
preferably be isolated from other facilities by walls 
and floors of fire resistive construction. 

Standard fire walls are recommended for the iso- 
lation of larger equipment and storage tanks, while 
partitions of plaster on expanded metal lath may be 
used to isolate smaller equipment from other com- 
bustible materials. 

Not less than two means of exit should be provided 
from each separate room or building in which VC^ 



is stored, handled or used. No portions of such a 
room or building should be farther than 75 feet from 
the nearest exit. Additional exits should be provided 
depending upon the number of persons in the build- 
ing (See NFPA Standard dilOl Life Safety Code ) 

All exit doors should open out in the direction of 
travel and should be provided with panic hardware 
Fire doors should open out in the direction of travel 
and be of an approved type. 

Operations where large quantities of VCM are 
used should preferably be housed in one story build- 
ings 



-35- 



APPENDIX C 



Vinyl Chloride 



Manufocfvring Chemists Association 



Explosion vents may be used lo reduce destructive 
damage to buildmgs. ducts, mixers, blenders, driers 
and similar equipment in which flammable vapors 
are liable to concentrate. 

Explosion venting windows, roof and wall panels, 
skylights, light windows, diaphragms, etc.. may be 
used to minimize building damage due to explosion 
pressures 

Since the required area of explosion vents depends 
upon such factors as the intensity of an explosion, 
vapor temperature, type of structure, the type of vent 
closure, etc., the determination of vent ratios should 
be made by experienced engineers and safety and fire 
protection specialists. Consideration may be given 
to explosion suppression systems (Reference: NFPA 
Fire Codes, Vol. 9— =68). 

The question of adequate spacing of chemical stor- 
age buildings from other buildings and processing 
equipment should be considered. 

A fire resistive stairwell with self-closing fire doors 
may be specified for hazardous operations on upper 
floors 

The need for segregating floor drains from sanitarv 
or process sewer systems should be considered. 

4.2 EQlIPMEVr DESIGN 

4.2.1 Processes should be designed so that op- 
erating personnel will not be exposed to direct con- 
tact with vmyl chloride or its vapor. The technical 
problems of designing equipment, providing adequate 
ventilation, and formulating operational procedures 
which promise maximum security and economy, can 
be handled best by engineers or other competent per- 
sonnel. The manufacturers of vinyl chloride, and of 
the equipment in which it is to be used, are always 
prepared to help with these problems. 

4.2.2 In the handling of vinyl chloride or opera- 
tion of any type of vinyl chloride system, all valves, 
pipe lines, vents, safety devices, etc., should be so 
located that they can be readily inspected and re- 
paired They should always be in proper order and 
condition before the operation is staned All handlmg 
and storage equipment should be located away from 
any source of sparks, flames, healed surfaces and all 
sources of ignition which might cause fires or ex- 
plosions. All charging and discharging pipes should 
enter through, or extend to, the bottom of all con- 
tainers to minimize vaporization of the liquid. Use 
of excess flow valves and valves with fusible links 
should be considered on storage tanks and other large 
vessels in case of fires or leaks near these vessels. 

4.2.3 It is essential for safely that equipment be 
used and maintained as recommended by the manu- 
facturer and that a periodic test schedule of the 
equipment, including safety devices, should be fol- 



lowed. All vent lines should extend outdoors to an 
area free of any source of ignition for discharge 
Vents and vent lines should have flash arresters 

4.2.4 Material of copper or copper-bearing allov 
should not be used in contact with vinyl chloride due 
to the possible presence of acetylene and the forma- 
tion of explosive acetylides 

4.3 VENTILATION 

4.3.1 Ventilation should be adequate to maintain 
exposures below the ceiling value of 500 ppm recom- 
mended by the U.S. Depanment of Labor 

4.3.2 If the workroom or operating area is sep- 
arate from vinyl chloride storage or processing equip- 
ment, general ventilation is usually adequate For 
emergencies, however, the area may be provided 
with mechanical exhaust ventilation to maintain con- 
centrations below 500 ppm Mechanical ventilators 
should be of the nonsparking or explosion-proof tvpe 
and should have motors conforming to the Nations' 
Electrical Code (Class I, Division I). 

4.3.3 In the processing or storage area, if outside 
location is impracticable, special emergcnc\ equip- 
ment for ventilation is necessary under abnormal 
conditions, such as leaks or spills. 

4.3.4 The most imponant consideration in ven- 
tilation is to ensure an adequate air flow awas from 
the work area 

4.3.5 All ventilating systems should be inspected 
periodically and maintained in a safe and efficieni 
working condition. 

4.3.6 Under abnormal conditions, such as when 
leaks or spills occur, all available ventilation should 
be used. 

4.4 AIR ANALYSIS 

4.4.1 Analysis of the air for vinyl chloride in the 
work area will give a measure of the effectiveness of 
engineering control of the vapors. It ma\ be per- 
formed to detect leakage of vapors from equipment 
and also to ascenain the order of magnitude of the 
health and fire hazard existing in work areas 

4.4.2 It should be kept firmly in mind that the 
use of the following instruments and test procedures 
for the detection of VCM in the air requires specially 
trained personnel. 

4.4.3 Vinyl chloride vapor concentrations in air 
near or within the explosive range are most easih 
determined by the use of a standard combustible gas 
indicator. The concentration of vapor may be read 
directly on the meter which is usually graduated in 
percent of the lower flammable limit The above 
should not be used for the detection of health haz- 
ards. 



APPENDIX C 



-36- 



Manufacturing Chemisis Associalion 



Vinyl Chloride 



4 4/ A specially calibrated indicator is commer- 
cially available for vinyl chloride monomer deter- 
mmations wiihm the toxic range Ampules which 
change color on exposure to VCM vapors arc also 
commercially available and may also be employed 
fcr the detection of low level concentrations. 



4 5 ELECTRICAL EQUIPMENT 

All electrical equipment, motors, lights, and flash- 
hghts used in an area in which vinyl chloride is 
stored or handled should conform to the National 
Electrical Code 



EMPLOYEE SAFETY 



5 1 EMPLOYEE EDlC.\TION AND 
TRAINING 

5.1.1 Before undcnaking any training of the em- 
ployees who are engaged in handling or processing 
viny' chloride the supervisor should be thoroughly 
familiar with the contents of this data sheet. MCA 
Case Histories describe accidents and injuries that 
have occurred while handling or processing vinyl 
chloride monomer. Safety specialists and suppliers 
may also be consulted. 

5.1.2 After becoming thoroughly familiar with 
the hazardous characteristics of vinyl chloride mono- 
mer, the supcnisor should review each procedure 
where the material is to be used and preferably with 
.k., occ;c...n,-p of the workers directly involved. Dur- 
ing the review all danger points should be identified 
and the precautionary measures determined The 
review should not only be concerned with the dangers 
of contact or exposure to vinyl chloride monomer, 
but also those which may be involved in handling 
containers, operating equipment and other aspects of 
the work. Procedures for all forseeablc emergencies 
should be established including the location and op- 
eration of safety showers, fire extinguishers, alarms. 
etc. and the need for personal protective equipment 

5.1.3 During the safety review of the operations 
it may become apparent that some danger points can 
be eliminated Possibly additional ventilation, ma- 
chine guarding or modifying the method of handling 
the material or containers can avoid potential haz- 
ards. Process changes, however, should never be 
made without the approval of those who have de- 
veloped the process and other knowledgeable per- 
sons In chemical processing even a slight deviation 
might have disastrous results. 

5.1.4 All significant hazards which cannot be 
satisfactorily guarded by rearrangement or other 
modification should be explained together with the 
precautions to be followed in the standard operating 
procedures. Preferably these safety precautions 
should be an integral pan of the operating instruc- 
tions. For example, if eye protection is required 
while taking a sample the sundard operating proce- 
dure might read. "Wear goggles and take sample 
from Still No. 000." This type of instruction is pre- 
ferable to explaining to the worker the need to take 
a sample and in another pan of standard operating 



procedure having a notation to the effect that he is 
to wear eye protection when sampling 

5.1.5 If there are extremely critical steps in the 
process where, for example, over charge or under 
charge may cause uncontrollable reaction, considera- 
tions should be given to making these supervisory 
check points In such instances the standard operat- 
ing procedure should specify that the employee must 
notify his supervisor before proceeding funher or as 
in this example, prior to charging the material to the 
reactor. It then becomes the supervisor's responsibil- 
ity to verify that the employee has followed the 
proper procedure before undertaking the critical step. 

5.1.6 The safety review described should be re- 
peated periodically for all chemical processing opera- 
tions and always following a significant change in the 
process 

5.2 PERSONAL PROTECTIVE EQUIPMENT 
5.2 1 Availahilily and Use 

Personal protective equipment is not an ade- 
quate substitute for good, safe working conditions, 
adequate ventilation, and intelligent conduct on the 
pan of employees working with VCM. It is, how- 
ever, in some instances the only practical means of 
protecting the worker, particularly in emergency sit- 
uations One should appreciate that personal protec- 
tive equipment protects only the worker wearing it, 
and other unprotected workers in the area may be 
exposed to danger. 

The effectiveness of personal protective equip- 
ment requires the training of workers in its proper 
use and care The following personal protective 
equipment should be used when indicated: 

5.2.2 Eye Proleclion 

Chemical Saiety Goggles 

Cup-type plastic or rubber framed goggles, 
equipped with the approved impact resistant glass or 
plastic lenses, should be worn whenever there is 
danger of the material coming in contact with the 
eyes. Goggles should be carefully fitted. 

5.2.3 Spectacle-Type Safely Goggles 

Metal or plastic rim safety spectacles with side 
shields may be used where continuous eye protection 



Vinyl Chloride 



-37- 



Monufocfuring Chtmiffi Aitociofion 



APPENDIX C 



is dcsirablo, as in laboratories Spectacles, however. 
should not be usod where complete eye protection is 
needed such as when handling bulk quantities, when 
there is danger of splashing, or when the material is 
under pressure. 

5.2 4 Face Shieldii 

Plastic shields (full length. 8" minimum) with 
forehead protection ma\ be worn in addition to 
chemical safety goggles where complete face protec- 
tion is desirable. Chemical safety goggles should 
always be worn as added protection where there is 
danger of material striking the eyes from underneath 
or around the sides of the face shield 

5.2.5 Respiratory Protection 

5.2.5 1 Severe exposure to VCM may occur in 
tanks during equipment cleaning and repairs, when 
decontaminating areas following spills, or in case of 
failure of piping or equipment Employees who may 
be subject to such exposures should be provided 
with proper respiratory protection. Available types 
are described below: 

Note: Respiratory protective equipment 
must be carefully maintained, inspected, cleaned and 
jlvirilizcd at regular intervals and always before and 
after use by another person 

(a) Self-contained Breathing Apparatus 
which permits the wearer to carry a supply of air 
compressed in the cylinder allows considerable mobil- 
ity. The length of time a self-contained breathing 
apparatus provides protection varies according to 
the amount of air carried Compressed oxygen must 
not be used where there is danger ol contact with 
flammable liquids, vapors, or sources of ignition, 
especially in confined spaces such as tanks or pits 
because of the increased fire hazard an oxygen rich 
atmosphere presents. 

(b) Positive Pressure Hose Masks which are 
supplied by blowers requiring no internal lubrication 
may be used The wearer must be able to use the 
same route for exit as for entrance and must take 
precautions to keep the hose line free of entangle- 
ment. The air blower must be placed in an area free 
of contaminants. 

(c) Air-line Masks, supplied with clean 
compressed air, are suitable for use only where con- 
ditions will permit safe escape in case of failure of 
the compressed air supply. These masks are usually 
supplied with air piped to the area from a compres- 
sor, it is extremely important that the air supply is 
taken from a safe source, and that it is not contami- 
nated by oil decomposition from inadequate cooling 
at the compressor The safer method is to use a 
separate compressor of the type not requiring in- 
ternal lubrication. Pressure reducing and relief 
valves, as well as suitable faps and filters, must be 
installed at all mask stations An alternate arrange- 



ment frequently used is high pressure breathing air 
from standard (200 cu ft ) cylinders, with a demand 
type valve and face piece. This arrangement ma\ 
also be used with 50-100 lb. clean piped plant air. 
and, as an additional precaution with the demand 
mask, a small cylinder of compressed air ma\ be 
worn for use as an emergency escape from the area 
Consult a reliable safety equipment dealer for detail^ 
on the proper use of U.S. Bureau of Mines approved 
equipment. 

(d) Industrial Canister-Type Gas Masks. 
equipped with full face pieces and approved by the 
U.S. Bureau of Mines, fitted with the proper canister 
for absorbing vapor, will afford protection against 
concentrations not exceeding 2 percent by volume 
when used in accordance with manufacturer's in- 
structions. The oxygen content of the air must not 
be less than 16 percent by volume. The masks should 
be used for relatively short exposure periods only 
They are not recommended for use in an emergcncv 
since, at that time, the actual vapor concentrations 
is unknown and an oxygen deficiency may exist The 
wearer must be warned to leave the contaminated 
area immediately on detecting the odor of a chemical 
vapor. This may indicate that the mask is not func- 
tioning properly, that the vapor concentration is too 
high, that the canister is exhausted or that the mask 
is not properly fitted. Because of the limitations out- 
lined, use of canister masks should be restricted 

Note: Where other gas having little or no 
odor may be encountered in addition to VCM the 
mask should be equipped with an "all purpose can- 
ister" and a "timing device" as approved by the U.S. 
Bureau of Mines. 

(e) Chemical Cartridge Respirators may be 
used to avoid inhaling disagreeable but relatively 
harmless concentrations of VCM vapor These res- 
pirators, however, are not recommended for protec- 
tion where toxic concentrations may be encountered 
or where there may be oxygen deficiency. 

CAUTION: Filter-type respirators do not offer 
protection against gases or O:.. deficiency and are 
unsuitable for use when working with VCM 

5.2.6 Head Proleclion 

"Hard" hats should be worn where there is dan- 
ger from falling objects. 

"Bump caps" arc satisfactory in areas where 
there is little or no hazard from falling objects. They 
will give protection from liquid leaks and splashes. 

5.2.7 Foot Protection 

Leather or synthetic rubber safety shoes with 
built-in steel toe caps are recommended where there 
is danger of heavy objects falling on a workman's 
foot. Liquid vinyl chloride penetrates leather, and 
shoes w;t with vinyl chloride should be (a) discarded 



APPENDIX C 



-38- 



Manufaciuring C/iemffts Association 



Vinyl Chloride 



if the riionomer is phenol inhibited, and (b) removed 
and not worn until thoroughly dr%' when handling 
uninhibited monomer. 

5.2.8 Body, Skin and Hand Protection 

5.2.8.1 Any work gloves, clothing or wearing 
apparel which becomes contaminated with \'CM 
should be removed immediately, and the body should 
be thoroughly washed All contaminated work 
gloves, clothing or weanng apparel should be thor- 
oughly washed, and dried before reuse. 



5.2.8.2 When cleaning, inspecting, or repair- 
ing tanks, safety equipment such as safety belts, 
rescue harness, lifeline, clothing and respiratory pro- 
tective equipment should be worn as required by the 
specific nature of the work and the hazards involved 

5 2.8 3 Frequent inspections and necessary 
repairs should be made to all personal prolectisc 
equipment so that it is always ready to give proper 
protection to the wearer 

5.2.8.4 Facilities for personal cleanliness 
should be provided 



FIRE FIGHTING 



6.1 When vinyl chloride bums, the hazardous gases 
generated are mostly hydrogen chloride and carbon 
monoxide (See 3.2.2). 

6.2 Emergenrv Measures 

(See 7,5.2) 

6.3 Fire involving large quantities of spilled liquid 
are difficult to extinguish since vinyl chloride is not 
misciblc with water and is lighter than water (will 
float on top of water). Most small fires can be ex- 
tinguished with carbon dioxide or dry chemical 



agents if properly applied Adequate fire extinguish- 
ing equipment of carbon dioxide or dry chemical 
type, fixed and ponable, should be provided Water 
fog or spray is also satisfactory for cooling. Diking 
and/or draining should be provided for confining and 
disposing of the liquid in case of tank rupture or 
spills. Precautions should be taken to guard against 
VCM entering the general sewer system. 
6.4 No one should be permitted to enter a fire area 
until it has been checked and approved for safe entry 
unless equipped with proper protective clothing and 
self-contained respirator. 



7. SHIPPING, LABELING, HANDLING AND STORAGE 



7.1 SHIPPING 

7.1.1 DOT Classification and Regulations 

Vinyl chloride monomer is classified by the U.S. 
Department of Transportation as a flammable com- 
pressed gas When shipped by rail, water or highway, 
it must be packaged in authorized containers and 
shippers must comply with all DOT Regulations re- 
garding packaging, loading, handling, labeling, mark- 
ing and placarding. 

7.1.2 Usual Shipping Container- 
Type and Size 

Cylinders— 4B1 50, 4BA225, 4BW225, 3A150, 
3AA150, DOT-25 and 3E-1800. 
Cylinders with brazed seams are not 
permitted. Maximum permitted fill- 
ing density — 84% 

Cargo Tanks — ^MC330 and 331 . Maximum per- 
mitted filling density — 84% 

Tank Cars— DOT 1 06 5(X) X Maximum filling 
density — 84% 



DOT 105 200 W Maximum filling 

density — 879"t 
DOT 1 1 2A 340 W Maximum filling 
density — 86% 
7.2 LABELTNG 

7.2 1 DOT Requirements 

7.2.1.1 Each container of vinyl chloride, in- 
cluding tank cars shall carry an identifying label 

7.2. 1 .2 The proper shipping name Vinyl Chlo- 
ride, as shown in tie commodity hst (para. 172.5) 
must be used and shown on the outside shipping con- 
tainers per para 172.1(a) and 173.401(a). 

7.2.1.3 Unless exempt, each individual con- 
tainer must bear the RED LABEL for FLAM- 
MABLE GASES as described in para. 173.408(a) 

7.2.1.4 DOT 177.823(b) requires that tank 
motor vehicles transporting VCM shall be marked 
on both sides and at the front and rear, with letters 
at least 4" high, with the words "FLAMMABLE 
GAS" or "FLAMMABLE COMPRESSED GAS." 



-39- 



APPENDIX C 



Vinyl Chloride 



Manufacturing Chemists Association 



In addiuon. the name "VrNYL CHLORIDE" must 
be displayed in letters at least 2" high The words 
"FLAMMABLL GAS" must he displavcd on other 
motor vehicles transporting 1000 lbs or more eros^ 
weight per para, 177.823(a). 

7 2 1 ."^ Each railroad car must bear the 
"DANGEROUS" placard per para 174.541 (a)(] ) 
.and (3). 

7.2.1.6 Para I73.402(a)n3) specifies thai 
an "EMPTY" label must be applied to containers 
which have been emptied and on which the old label 
has not been removed, obliterated, or destroyed. It 



must be so placed on the container as to completely 
cover the old label. 

7.2.17 Para. 174.562(b) specifies that a 
"DANGEROUS-EMPTY" placard shall replace 
or cover the"Dangerous" placard on the railroad 
tank car which ha.' been emptied. 

7.2 2 Precaulionani Labeling 

7.2.2.1 The Manufacturing Chemists Associa- 
tion recommends thai all containers of VCM should 
bear a label as shown. The text is desimcd for the 
product as shipped for industrial use It should be 



VINYL CHLORIDE 

DANGER! EXTREMELY FLAMMABLE LIQUID AND GAS 
UNDER PRESSURE 

HARMFUL IF INHALED 

MAY POLYMERIZE VIOLENTLY UNDER FIRE 
CONDITIONS OR LOSS OR REMOVAL 
OF INHIBITOR 

Keep away from heat, sporks, and open flame. 

Keep container closed. 

Use with adequate ventilation. 

Avoid breathing vapor. 

Avoid contact with skin. 

Keep cylinder out of sun and away from heat. 

Container should be grounded when being emptied. 

Never drop cylinder. 

FIRST AID: If inholed, remove to fresh air. If not breathing give 
ortificial respiration, preferably mouth-to-mouth. If breathing Is 
difficult, give oxygen. Coll a physician. 

In case of: 

Fire — Use water spray, dry chemical, or CO;. 
Spill or Leak —For small spills, evacuate area and permit to 
evoporote. For large spills or leaks, evacuate area. Dike 
or flush to ground and let evaporate. Do not flush to 
sewer because of explosion hazard. 
MCA Chamlcal Safety Data Sht«t SD-56 available. 



APPENDIX C 



-40- 



Manufocfuring Chemitis Astociaflon 



Vinyl Chloride 



used in addition to or in combination with any spe- 
cific wording required by law. Since individual 
statutes, regulations, or ordinances may require that 
particular information be included in a label, that 
certain information be displayed in a particular man- 
ner, o: that a specific label be affixed to a container. 
the use of this label text will not occessarily insure 
compliance with such laws. Such laws include the 
Federal Hazardous Substances Labeling Act; Federal 
Insecticide, Fungicide and Rodenticide Act; and 
similar state and municipal legislation. 

7.3 CYLINDERS 

7.3.1 Magnets or slings should never be used to 
unload cylinders. When transporting by crane or 
derrick a suitable platform, cradle or boot should 
be used. 

7.3.2 Care should be exercised not to drop cylin- 
ders or otherwise handle them roughly. 

7.3.3 Cylinders may be moved by tilting and 
rolling them on their bottom edge. Dragging and 
sliding them should be avoided. 

7.3.4 When cylinders are transported by hand 
'.r.:zy., they should be held securely in position by 
means of a locking clamp, chain or other suitable 
holding device. 

7.3.5 Cylinders should never be used as rollers 
for moving any object or material 

7.3.6 Valve protection caps should always be 
kept in place except when the VCM containers are 
connected to piping, apparatus or equipment As 
soon as a cylinder is disconnected the protective cap 
should be replaced. 

7.3.7 Avoid disturbing the fusible plug The 
safety device should be tagged in order to differen- 
tiate it from the discharge connection 

7.3.8 The area where the cylinder is connected 
should have adequate ventilation to prevent the 
build up of concentrations in the event of a leak. 

7.3.9 Cylinders should be provided with pressure 
regulators as recommended by the supplier. 

7.3.10 A water bath heated to a maximum of 
50 °C. (122°F.) may be used to empty cylinders by 
means of the vapor pressure of the vinyl chloride. 

7.3.11 Check valves must be installed in feed 
lines from the cylinder to prevent the reactants from 
entering the cylinder. 

7.3.12 When the cylinder is empty, the valve 
should be securely closed. Air must not be allowed 
to enter the container. 

7.3.13 Cylinders must not be filled except by or 
with the consent of the owner, and then only in 
accordance with DOT Regulations. 



7.3.14 Return of Cylintlerc 

The cylinder valve protection cap or outlet cap 
must be securely replaced. The lower ponion of th^ 
DOT shipping tag. if attached to the cylinder, mu<^! 
be removed In other cases, applicable to DOT 
Regulations, compliance is essential Bill of ladinc 
should giic the cylinder identifieallon number (whk-fi 
appears on the shoulder of cylinder) for each cylin- 
der shipped, show name of consignee and indicate 
that the cylinders are empty. 

Full or panly emptied cylinders should not be 
returned without permission of the supplier Such 
cylinders must be shipped as full cylinders and corre- 
spondingly labeled and tagged All empty cylinders 
should be returned promptly 

7.4 TANK CARS 

7.4.1 Because of the flammable and toxic prop- 
erties of VCM the unloading of tank cars is a hazard- 
ous operation The supplier should be contacted 
for instructions and the instructions closely followed 

7.4.2 DOT Regulations. Para 174.560 to 
174.563 inclusive, contain instructions which must 
be observed. 

7.4.3 Cars should be unloaded only on private 
sidings 

7.4 4 Shipper's instructions should always be fol- 
lowed and all caution markings on both sides of tank 
and dome should be read and observed, 

7.4.5 No heat should be applied to the tank car. 
An inert gas line or compressed vinyl chloride gas 
line should be attached to vent connection of the 
tank car to provide a pressure for transfer of the 
liquid vinyl chloride from tank. Transfer may also be 
by pumping, 

7.4.6 Cylinder nitrogen (inen gas) is often used 
as the pressuring medium in the event vinyl chloride 
gas is not available. Larger installations may have a 
suction line connected from the storage tank to a 
compressor which discharges compressed vinyl chlo- 
ride gas to vent connection on tank car. The pres- 
sure on the car should never exceed the service pres- 
sure at which the safety valve is set to operate, 

7.4.7 Return of Tank Cars 

As soon as a tank car is completely unloaded. 
all valves must be made tight, the unloading connec- 
tions must be removed and all closures made tight 
Air must not be permitted to enter the vessel. The 
inert gas used for the unloading procedures should 
be left in the vessel at a pressure not to exceed the 
service pressure for which the car was designed, but 
sufficient to prevent forming a vacuum in cold 
climates. 



-41- 



APPENDIX C 



Vinyl Chloride 



Manufacturing Chemists Association 



7.4.8 The DOT DANGEROUS placards on 
sides and ends of tank cars must be removed, or 
reversed (if in metal placard holders) by the party 
discharging the tank car. The empty car must be 
offered to the receiving carrier either without plac- 
•rds. or preferablv with four (4) DANGEROUS- 
EMPTY placards,' 

7.5 TRANSPORTATION EMERGENCIES 
7. SI Aasislanre Available 

7.5.1.1 CHEMTREC (CHEMical TRanspor- 
tation Emergency Center) 

This center, located in Washington. D. C. at 
the offices of the Manufacturing Chemists Associa- 
tion, is manned 24 hours per day, seven days a week, 
and provides, by telephone, immediate response' 
action information for police, fire-fighters and others 
concerned with the control of chemical transportation 
emergency situations. For assistance, dial 

•(800) 424-9300 in the 48 contiguous 
States of the USA 
483-7616 in District of Columbia 

•(200) 483-7616 in Alaska 

In Canada, call Canadian Chemical Produc- 
ers Association's TEAP (Transportation Emergencv 
Assistance Plan). 

• Use long distance prefix if needed 

7.5.1.2 Company Mutual Aid 

A number of vinyl chloride manufacturing 
companies voluntarily participate in a mutual-aid or- 
ganization under which, in the event of a transporta- 
tion accident, the closest company VCM plant will 
dispatch a qualified adviser to the scene of the acci- 
dent if requested to do so by the shipper of the 
commodity. 

7.5.2 Emergency Control 

7.5.2. 1 Pertonnel Attending Accident 
Scene 

Shippers' representatives do not take charge 
of emergency operations. They are present as ad- 
visers only. 

7.5.2.2 Recommended Emerfeney Kit 

The foUowing are considered essential : 

a. Explosion meter 

b. Self-contained air supply 

c. Wood plugs and wood mallet 

d. Data sheet and pencil 

e. Camera and film 

f . Flashlight (Bureau of Mines approved ) 



g. Rubber gloves 
b. Slicker suit 
i. Rubber overshoes 

j. Safety lines (braided stainless plastic cov- 
ered) and harness 
k. Goggles 
1. Safety bat 
m. O-rings 
n. Strap wrench 

0. 10" adjustable wrench 
p. Screwdriver 

q. Ground continuity meter 

r. Large first aid kit and collapsible water 
container, approx. 50 gals The water 
container should be filled at the emer- 
gency site and be available for eye 
wash or treatment of chemical skin 
contacts. 

7.5.2.3 Recommended Procedures 

Leaks of Vinyl Chloride 

1. Controllable Leaks 

a. Small holes: Drive wooden plugs 

b. Larger holes: Neoprcnc patch. 

bonded or chained to tank Spe- 
cial rigs should be left to the judg- 
ment of the man at the scene 

c. Jagged holes are difficult to close 

d. Potassium bicarbonate will extin- 

guish a vinyl chlondc fire but 
reignition often occurs Use it 
around valves if it appears that a 
leak can be subsequently con- 
Uolled. 

II. Uncontrollable Leaks — No Fire 

a. Isolate area. 

b. Remove sources of ignition. 

c. CoDtrcri spread of vapors by water 

spray. 

III. Uncontrollable Leaks — Fire 

a. Evacuate and isolate area. 

b. Keep adjacent cars cool, if possible. 

with water spray. 

c. Keep unofficial personnel away 

d. Treat i non-burning tank car in 

vicinity of fire as if it is about to 
rupture. 



APPENDIX C 



-42- 



Moninl 

ihMt 

SD-5i 



Monirfacfuring Chamisfi Association 



Vinyl Chloride 



e. If vinyl chloride gets to a sewer, 
evacuate area and flush sewers 
with fire hoses. 

7.5.2 4 SpWed Vinyl Chloride 

Spilled vinyl chloride should not be deliber- 
ately ignited. 

7.5.2.5 Recovery or Removal of 
Vinyl Chloride 

Depending upon circumstances and extent of 
car damage. VCM may be recoverable, but recover, 
should not be the determining factor in controlling 
the situation. 

a. If car condition permits, transfer contents 

to empty tank car using nitrogen pres- 
sure. 

b. If car is ruptured, attempt to use pump 

with flooded suction. 

c. If pumping is impractical, use water or 

oil to float out remainder of VCM. 

d. Fill empty tank with water or nitrogen. 

p Tf a vinyl-ice mixture forms, keep a water 
stream to the tank until it dissipates 

f. Handling of vinyl chloride in a damaged 
car can be influenced by weather con- 
ditions. At low temperatures, since 
vaporization is reduced, patch tank, if 
possible, so that it can be moved. 

7.5.3 Marine Einergenrie» 

7.5.3.1 U.S Coast Guard regulations require 
that a cargo information card for vinyl chloride be 
carried aboard the tank barge mounted near a warn- 
ing sign and in such a position as to be easily read by 
a man standing on the deck of the barge The cargo 
information card shall also be carried on the bridge 
or in the pilot house of the towing vessel Copies arc 
available from the Manufacturing Chemists Associa- 
tion. 

7.5.3.2 Special Safely Eguipmeiil 

In addition to normal safety equipment pro- 
vided at the dock, the following special items should 
be available : 

a. Self-contained breathing equipment (at 
least two with two spare bottles). 

- b. Explosimeters. 

c. Ground continuity meter. 

d. Water with an appropriate number of 

nozzles. 

e. Dry chemical fire extinguisher. 



f. MCA Chemical Safety Data Sheet SD-56 
and Cargo Information Card ClC-80 

.5.3 3 Recommended Emergency 
Procediiret 

7.5.3.3.1 Leaks oj Vinyl Chloride 

I. General — Activate .\larm 

II. Controllable Leaks — No Fires 

a. Isolate leak from source. 

b. Eliminate ignition source 

c. Control spread of vapors by water 

fog. 

d. Attempt to repair leak using ade- 

quat, safety protection proce- 
dures 

III. Uncontrollable Leaks OR 
Ruptures — No Fires 

a. Isolate area. 

b. Remove all sources of ignition. 

c. Use water spray to prevent ac- 

cumulation of liquid and to 
dissipate vapor cloud It is not 
recommended that the ship's 
fire water supply be booked 
into the city water supply.) 



IV. 



-Fire 



Uncontrollable Leaks- 

a. Isolate area 

b. Evacuate area except for emer- 

gency personnel. 

c. Use water fog on fire and fumes 

(do not extinguish fire unless 
leak can be controlled). 

d. Use copious amounts of water to 

keep adjacent areas cool. 

e. Treat adjacent tanks as if about 

to rupture, 

f. Make provisions to minimize the 

mixing of air with VCM vapor 
in confined spaces and the 
burning tanks or line (water, 
N; or inert gases). 

7.5.3.3.2 Spilled Vinyl Chloride 

Spilled VCM should not be deliberately 
ignited. 

7.5.3.3.3 Recovery or Removal oi 
Vinyl Chloride 

Depending upon circumstances and the ex- 
tent of the tank damage VCM may be recoverable 



-43- 



APPENDIX C 



Vinyl Chloride 



Manufocturing Chemists Association 



but pro\ 



isions musi be made to keep air out of the 

a If tank condition permits, transfer con- 
tents to an empt> tank or back to 
shore. 

b. If tank cannot be patched and it does 

not haNe a deep well pump or the 
deep well pump cannoi be used, 
sparge healed nitrogen into the bot- 
tom of the tank to vaporize the 
VCM. 

c. Fill empty tank with water or inert gas 



7.6 STORAGE 

7.6 1 VCM should always be handled with full 
recognition of its flammabilit>. Precautions should 
be taken both to keep the material enclosed and to 
eliminate sources of ignition. 

7.6.2 Corrosion 

VCM is noncorrosive at normal atmospheric 
temperatures when dry (moisture free) In contact 
with water at elevated temperatures VCM accelerates 
corrosion of iron or steel. 

7.6.3 VoUtiliiy 

VCM is very volatile and is a gas at normal 
atmospheric conditions Containers used for han- 
dling VCM at ambient temperature are usualls under 
pressure. 

7.6.4 Temperature Requirements 

Uninhibited VCM may be stored either under 
refrigeration or at normal atmospheric temperature 
in the absence of air or sunlight Regular checks 
should be made for the presence of polymers 

7.6.5 Conditions of Storage 

7.6.5.1 Type of Construction 

All piping (including instruments leads), 
storage stanks, relief devices and equipment em- 
ployed to handle VCM should be of steel and de- 
signed to have a working pressure of at least 100-150 
psi with a safety factor conforming to the A.S.M.E. 
code for unfired pressure vessels or any code applying 
to locale of planned storage. Shut-ofT valves and con- 
trol valves should be of steel or a suitable alloy not 
bearing copper, designed for working pressures of 
150 psi or over. All-welded construction is preferred 
to riveted construction. It is recommended wherever 
possible that all liquid inlet lines enter the bottom or 
extend to the bottom of the vessel. This aids in 
guarding against the accumulation of static electric- 
ity. All equipment should be properly grounded and 
bonded with resistance to ground never exceeding 25 



ohms. Electrical lighting, wiring and equipment 
should conform to NEC. An efficient water spra\ 
system should be installed or made availab!; Ade- 
quate diking and/or draining should be provided 
under tank area to confine and dispose of the liquid 
in case of vessel rupture. Cylinders used to store 
VCM must meet DOT Specifications 

765.2 Isolation 

Storage areas should be selected m accord- 
ance with local codes or authorities having jurisdic- 
tion. For highh volatile and flammable maiena!. 
storage should be located outside of buildings Cylin- 
ders containing \'CM should be stored aluavs in a 
vertical position, outside of buildings, and in an iso- 
lated and well ventilated area It is preferable tc 
store cylinders in the open, but provision should be 
made to shield them from the direct rays of the sun 
and prevent accumulation of din, snow, water, or 
ice on valves or safety devices 

7.6.5.3 Compatible and Dangerously 
Reactive Materials 

Tanks in VCM service should be used onh 
for the storage of VCM Before VCM is placed in a 
tank, the vessel should be purged with a dr^ inert gas 
imtil free of oxygen. VC^ is generalh noncorrosive 
at normal atmospheric temperatures when drv (mois- 
ture free). However, mild to appreciable corrosion 
has been noted when wet, even at ordinary tempera- 
ture. This may be due to the presence of impurities 
In contact with water at elevated temperatures VCM 
accelerates corrosion of iron or steel. Acetylene as 
as impurity in VCM may form an explosive com- 
pound (acetylide) when exposed to copper or pos- 
sibly copper alloys. 

7.7 REPACK_4GING 

7.7.1 Only clean, DOT Specification cylinders 
should be used. 

7.7.2 Adequate ventilation should be provided 
and all sources of ignition removed from transfer 
area 

7.7.3 Proper personal protective equipment 
should be used. Transferring VCM from cylinders 
by the use of an uncontrolled heating method is not 
recommended. Temperatures of over 50'C (122°F.) 
should not be applied to any part of a cylinder con- 
taining compressed gas. Excessive heating weakens 
the structural characteristics of the metal and may 
seriously damage the cylinder. Low melting safet\ 
devices may reach the fusing point by the application 
of excessive heat to a cylinder. Never apply direct 
fiamc to a cylinder. A definite fire hazard is created 
For recommended practice to transfer contents of a 
cylinder see 7,3. 



APPENDIX C 



-44- 



Manufocfunng Chsmlsts Association 



Vinyl Chloride 



TANK AND EQUIPMENT CLEANING AND REPAIRS 

(See MCA Safely Guide SG-10 "Entering Tonki and Olher Encloied Spaces") 



8 1 JOB EVALUATION AND PREPLAN?flNG 

8.1.1 Because vinyl chloride monomer has phys- 
ical and chemical properiici which general- hazards 
of a toxic and flammable nature, tank and equipment 
cleaning and repairs should be conducted in such a 
manner as to eliminate or minimize the hazards. (See 
10.1.1 Health Hazards — Note concerning Acroosteo- 
lysis.) 

8.1.2 Equipment and tank cleaning and repair 
should be under the direction of thoroughly trained 
personnel who are fully familiar with all of the haz- 
ards and the safeguards necessary for the safe per- 
formance of the work. All precautions penaining to 
education, protective equipment, and health and fire 
hazards should be reviewed and understood. 

8.1.3 The hazardous nature of tank inspection, 
cleaning, and repair requires that the foreman and 
crew be selected, trained, and drilled carefully. They 
should be fully familiar with the hazards and the safe- 
guards necessary for the safe performance of the 
work. The preparation of a stepwise work procedure 
for the entire job, recognizing all possible hazards as 
they might occur, developing safe procedures and 
designating suitable protective equipment, has been 
found to be particularly effective in maintaining work 
safety. 

8.1.4 A written work permit must be prepared 
before tank preparation and entry It must describe 
work procedures to be used, hazards which may be 
encountered and procedures and equipment to be 
used to nullify these hazards. It must be prepared, 
reviewed and signed by the supervisor to whom the 
tank is assigned after they have satisfied themselves 
that tank entry and repair work can be done safely. 

8.2 TANTv OR EQUIPMENT CLEANING 

8.2.1 Tanks and equipment, pumps, lines and 
valves should normally be drained and thoroughly 
cleaned before being repaired. Workmen should 
never be allowed to attempt to repair equipment 
while it is in operation and the lines in service unless 
special precautions are used such as "Hot Tap" 
work. 

8.2.2 Smoking, use of open flames, and the pres- 
ence of unauthorized personnel should be prohibited. 

8.2.3 All lines, which may contain hazardous 
substances, entering or leaving the tank should be 
blanked. After draining, the tank should be flushed 
with water to remove any remaining VCM liquid 
The tank should then be steamed to remove residual 
VCM. Water and steam lines and nozzles should be 



grounded to minimize hazards of static electricity 
The tank should then be cooled by filling with water 
and draining. Finally, the tank should be purged 
with fresh air and then tested for VCM by an ap- 
proved method It should also be tested for oxygen 
sufficiency. The controls for all agitators, pumps and 
other electrical equipment connected to the tank 
should be padlocked by the worker entering the tank. 

8.3 ENTERrSG TANK 

8.3.1 No one should enter a tank or confined 
space until a work permit has been signed by an 
authorized person indicating that the vessel has been 
properly prepared, tested and found to be safe. 

8.3.2 No workman should enter a tank or vessel 
that does not have a manhole opening large enough 
to admit a person wearing a safety harness, lifeline 
and emergency respiratory equipment. 

8.3.3 Forced air ventilation is recommended dur- 
ing the entire time men are cleaning, repairing or 
inspecting the tank. Ventilation can be accomplished 
by exhausting or removing vapors from the bottom 
of the tank either through a bottom opening or 
through a large flexible duct Blowers should be 
sparkproof and should not be allowed to overheat 
and thus provide a source of ignition. All men who 
enter the tank should wear a safety harness and life- 
hne. 

8.3.4 When a tank car or storage tank is being 
cleaned or repaired one man on the outside of the 
tank should keep the men in the tank under observa- 
tion. This man should not leave his post or enter the 
tank without first obtaining a substitute. Another man 
should be available nearby to aid in rescue if any of 
the men in the tank are overcome. 

8.3.5 Suitable respiratory protective equipment, 
together with rescue harness and lifeline, should al- 
ways be located outside the tank for rescue purposes 

8.3.6 During the course of the work, frequent 
air samples should be taken to see that the concen- 
trations are within safe range 

8.3.7 If repair work is interrupted, the tank at- 
moshere should be tested and a new work permit 
issued before work is resumed. 

8.4 EMERGENCV RESCUE 

8.4.1 A rescuer should not enter a confined 
space without wearing approved respiratory protec- 
tive equipment, a safety harness and an attached 
lifeline. Another employee should be immediately 



-45- 



APPENDIX C 



Vinyl Chloride 



Manufacturing Chemisis Auociotii 



Monuol 
SD-5» 



available to man the lifeline and to assist in tlie 
rescue if needed The rescuer should be in view of 
the outside attendant at all limes or in voice com- 
munication with him. 

8.5 EXTERIOR REPAIR WORK 

A!! outside welding, burning or spark-producing 
work on tanks or equipment which have contained 



VCM should be done after the container has been 
thoroughly cleaned of VCM vapors Purging should 
be tested by a competent person to see if it is free of 
VCM. It is not recommended that air be used to 
purge a vessel. 

If the repair work is interrupted, the tank atmos- 
phere should be checked thoroughly and a nc* work 
permit issued before resumption of work 



9. WASTE DISPOSAL (See 7.5) 



9.1 All Federal. State, and Local regulations re- 
garding health and pollution should be observed 
Disposal of waste material, however, depends to a 
great extent upon surroundings, weather conditions 
and the emergency making disposal necessary. 

9.2 When it becomes necessary to dispose of VCM 
as such, it is preferable to do so as a vapor, venting 
to an area free of any source of ignition. 



9.3 When a waste disposal problem arises as a 
result of a major spill or equipment rupture, onl\ 
properly protected and qualified personnel should 
remain in the area. 

9.4 Waste mixtures containing VCM should no! be 
allowed to enter drain or sewers as serious explosions 
in such systems may result 



10. MEDICAL MANAGEMENT 



;o; HEALTH HAZARDS 

10.1.1 Vinyl chloride monomer docs not present 
a serious industrial health hazard provided workers 
are adequately supervised and observe the proper 
means of handling it Under the Occupational Safety 
and Health Act. the U.S. Department of Labor has 
set a 500 ppm Ceiling Value on permitted employee 
exposures Based upon animal and human observa- 
tions, this level provides considerable margin of 
safety for industrial exposures. 

Note; A syndrome termed occupational acro- 
osteolysis. characterized primarily by Raynaud's 
phenomenon and osteolytic changes in certain bones, 
particularly the distal phalanges of the hands, has 
been noted among certain workers in vinyl chloride 
polymerization operations. The specific cause of this 
disease, and particularly any role played by vinyl 
chloride, is unknown. 

Recent research studies reported from Italy in- 
dicate that repeated, long-term high level exposures 
of rats to vinyl chloride monomer vapor can result in 
the development of malignant tumors. However, 
many years of industrial experience with human ex- 
posures to concentrations frequently far above cur- 
rent standards have not demonstrated any carcino- 
genicity to humans. 

10.1.2 Acute Toxicity 

Levels on the order of 6,000 ppm for five 
minutes exposure are required to produce minimal 



symptoms resembling mild alcohol intoxication in 
humans. Levels approximatcK 16,000 ppm for the 
same length of time will produce varying degrees of 
intoxication, with lighi-headedness, some nausea, and 
a dulling of visual and auditory responses in mosi 
humans. 

10.1.3 Chronic Toxicity 

The liver is the principal target resulting from 
excessive chronic exposure. The currentl\ recom- 
mended ceiling level (OSHA) of 500 ppm is well 
below a level producing any signs or symptoms of 
toxicity. 

10.2 PRE>'EVnVE MEASURES 

10.2.1 All operations in which vinyl chloride is 
used should be regularly evaluated and atmospheric 
concentrations kept, at all times, below 500 ppm 
Sophisticated air sampling techniques arc required 
This includes gas chromatograph\ . Processes musi 
be closed or ventilated sufficiently to achieve a con- 
centration control low enough so that respiratory 
protection devices are needed only on an emergency 
basis. 

10.2.2 Personal Hygiene 

Vinyl chloride should be kept off the skin and 
out of contact with the eyes. If accidental contact to 
the skin occurs, immediate washing with soap and 
water is necessary; if to the eyes, immediate irrigation 



APPENDIX C 



-46- 



Manuiacfuring Chemisis Association 



Vinyl Chloride 



for a minimum of 15 mmutes with water is required. 
The pesencc of skin and eye washing equipment in 
the areas where vinyl chloride is used is necessary. 

Washing supplies and equipment should be 
maintained and always immediately available. 

10.2.3 Physical Examinations 

Prcplaccment examinations should be made on 
all workers having potential exposure to vinyl chlo- 
ride, with particular emphasis placed upon liver and 
kidney functions. 

10 3 SI GGESTIONS TO PHYSICIAN? 

Treatment for vinyl chloride intoxication is symp- 
tomatic, no special procedures are required. It 
should be recognized that the principal target of 
chronic exposures is the liver, with secondary effects, 
particularly in acute exposures, to the kidney. In 
acute overexposures the primary effect is on the 
central nervous system. 

Note to Physician; Avoid use of epinephrine or 
related drugs in treating acute overexposure cases 
since vinyl chloride may sensitize the heart to the 
arrhythmic action of these drugs 

10.3.1 Oxygen AHminislration 

Oxygen has been found useful in the treatment 
of inhalation exposures of many chemicals, especially 
those capable of causing either immediate or delayed 
harmful effects in the lungs 



In most exposures, administration of lOOTc 
oxygen at atmospheric pressures has been found to 
be adequate. This is best accomplished by use of a 
face mask having a reservoir bag of the non-re- 
breathing type. Inhalation of 1009c oxygen should 
not exceed one hour of continuous treatment After 
each hour, therapy may be interrupted. It may be 
reinstituted as the clinical condition indicates. 

Some believe that superior results are obtained 
when exposures to lung irritants are treated with oxy- 
gen under an exhalation pressure not exceeding 4 cm 
water. Masks providing for such exhalation pressures 
are obtainable. A single treatment may suffice for 
minor exposures to irritants It is believed by some 
observers that oxygen under pressure is useful as an 
aid in the prevention of pulmonary edema after 
breathing irritants 

In the event of an exposure causing symptoms or 
in case of a history of severe exposure, the patient 
may be treated with oxygen under 4 cm. exhalation 
pressure for one-half hour periods out of every hour. 
Treatment may be continued in this way until symp- 
toms subside or other clinical indications for inter- 
ruption appear 

CAUTION: It may not be advisable to ad- 
minister oxygen under positive pressure in the 
presence of impending or existing cardiovascular 
failure. The use of adrenalin is not recommended 
because some chlorinated hydrocarbons can increase 
the risk of ventricular fibrillation after adrenalin 
therapy. 



1 1. FIRST AID 



11.1 GENER.4L PRINCIPLES 

First aid should be started at once in case of acute 
intoxication with vinyl chloride. Immediately re- 
move the affected individual to fresh air. Refer all 
injured individuals to a physician and give a detailed 
account of the incident. 

11.2 CONTACT WITH SKIN AND 
MLCOLS MEMBRANES 

Vinyl chloride, in concentrated form, is a skin irri- 
tant. All contaminated clothing should be removed 
at once; and this clothing, including shoes, if there is 
any evidence of contamination, should not be worn 
again until thoroughly dry. All affected skin areas 
should be thoroughly washed with warm water and 
soap The individual should be referred to a physi- 
cian. 

11.3 CONTACT WITH E^"ES 

If vinyl chloride has entered the eyes, prompt 



washing with copious quantities of water for at least 
15 minutes should be instituted immediately. It is 
advisable to irrigate the eyes gently with water at 
room temperature in order to minimize additional 
pain and discomfort. Prompt medical attention 
should be obtained. 

1 1 4 INHALATION 

Promptly remove the affected individual from ex- 
posure, to fresh air If breathing has ceased effective 
artificial respiration should be started immediately 
If oxygen inhalation equipment is available oxygen 
should be administered, provided a person authorized 
for such administration by a physician is available. 
The patient should be comfortably warm but not hot 
Stimulants will rareK be necessary where adequate 
oxygenation is maintained. Any such drugs for shock 
treatment should be given only by the attending 
physician Never auempi to give anything by mourit 
lo an unconscious patiem. 



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